Draft regulations: Offshore Receipts in respect of Intangible Property
Detail of outcome
We received 12 written responses - mainly from advisory firms, representative bodies and businesses affected by the rules.
The Statutory Instrument has been updated to reflect the comments received.
There are clarifications to the definition of UK sales to make the rules more proportionate and improve their targeting as well as new rules to minimise double taxation, and better targeting of the jurisdictions in scope. We have also published the tax information and impact note.
You can read:
- the updated statutory instrument
- the supporting explanatory memorandum
- the tax information and impact note
- updated draft technical guidance (see below)
Original consultation
Consultation description
The government introduced legislation in Finance Act 2019 that extends the types of income on which non-UK residents are liable to UK Income Tax, known as ‘Offshore Receipts in respect of Intangible Property’ (ORIP). This came into effect on 6 April 2019.
This is a technical consultation on the (draft) Income Tax (Trading and Other Income) Act 2005 (Amendments to Chapter 2A of Part 5) Regulations 2019 that amends the ORIP legislation.
The publication of these regulations follows the summary of responses to the consultation on Royalty Withholding Tax and further consultation with stakeholders.
Before submitting your response for this consultation, you can read:
- draft regulations
- explanatory memorandum
- draft guidance
Documents
Last updated 14 October 2019 + show all updates
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Added draft technical guidance and outcome summary, including links to the statutory instrument and explanatory memorandum on The National Archives website.
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First published.