http://www.legislation.gov.uk/ukpga/2005/5/section/15Income Tax (Trading and Other Income) Act 2005An Act to restate, with minor changes, certain enactments relating to income tax on trading income, property income, savings and investment income and certain other income; and for connected purposes.texttext/xmlenStatute Law Database2026-07-30Expert Participation2026-07-15 Part 2Trading incomeChapter 2Income taxed as trade profits<Emphasis>Trades and trade profits</Emphasis>Divers and diving supervisors151This section applies if—aa person performs the duties of employment as a diver or diving supervisor in the United Kingdom or in any area designated by Order in Council under section 1(7) of the Continental Shelf Act 1964 (c. 29),bthe duties consist wholly or mainly of seabed diving activities, andcany employment income from the employment would otherwise be chargeable to tax under Part 2 of ITEPA 2003.2The performance of the duties of employment is instead treated for income tax purposes as the carrying on of a trade in the United Kingdom.3For the purposes of this section the following are seabed diving activities—ataking part as a diver in diving operations concerned with the exploration or exploitation of the seabed, its subsoil and their natural resources, andbacting as a diving supervisor in relation to any such diving operations.