Temporary work places

What are peoples opinions of whether the following is a temporary workplace

 

Newly recruited employees from East Yorkshire are to be employed to work on a boat that is to be hired out to a third party for maintenance of the wind farms in the North Sea. The boat is going to be berthed in Ramsgate and will require a crew of four split into two groups of two individuals each working 12 hour shifts. Two crew members will work from 7am to 7pm and the other two will work from 7pm to 7am.  The contract given to the employees will stipulate they may be employed anywhere in the UK.  The term will initially be for 6 months but potentially longer if the contract is renewed with the third party, at which point the ship is likely to depart from East Yorkshire.

 

The employer wants to pay travel costs from East Yorkshire to Ramsgate for each employee and subsistence (as reasonable and document supported) whilst they are down there and to also rent a house close to the place of departure for the ship.

 

Do these payments give rise to a taxable benefit in kind?

 

S305 ITEPA 2003 exempts overnight accommodation close to the place of departure for offshore oil and gas workers.  EIM34110 elaborates on this as to what HMRC regard as offshore installation http://www.hmrc.gov.uk/manuals/eimanual/eim34110.htm

 

1 - I do not think this is a temporary workplace due to S339(5)(a)(ii)

2 - I am not convinced they are involved with offshore installation that qualifies for the exemption under S305

 

For a work around I how about employing these new recruits work on ships departing from East Yorkshire and seconding a current recruits down to Ramsgate for 6 months and alternating them in future if needs be, can anyone see any problems with this?