Revenue’s Tax and Duty Manual has been updated to confirm that where the crew of a fishing vessel is reasonably stable from one fishing voyage to the next, the same partnership can be considered to cover multiple fishing voyages. Whether this treatment can apply will need to be considered on a case-by-case basis.
This direction from Revenue follows the determinations in two previous cases in 2001, Francis Griffin v The Minister for Social, Community and Family Affairs and Wm. Deasy v The Minister for Social, Community and Family Affairs where it was confirmed that share fishermen were partners in a partnership and that each venture out to sea was a separate partnership. Revenue’s eBrief 118/22 has more details.