Consultation outcome

Royalty withholding tax

• From: HM Revenue & Customs and HM Treasury
• Published: 1 December 2017
• Last updated: 24 May 2019, see all updates

This consultation has concluded

Download the full outcome

Offshore receipts in respect of intangible property (previously Royalties Withholding Tax) - Summary of Responses

PDF, 503KB, 27 pages

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Offshore receipts in respect of intangible property - draft legislation

PDF, 721KB, 12 pages

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Offshore receipts in respect of intangible property - Explanatory Note

PDF, 260KB, 8 pages

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Detail of outcome

The information on this page is out of date (as of May 2019). Please see the consultation on draft regulations for offshore receipts in respect of intangible property.

We received 21 written responses mainly from law firms, accounting firms, market operators and representatives and would like to thank everyone who contributed.

This response summarises the submissions received to the consultation and accompanies the publication of the legislation ‘Offshore Receipts in respect of Intangible Property’.

We have also published draft legislation, a supporting explanatory note and a tax information and impact note.

A full draft of the legislation will be published with the rest of the Finance Bill 2018 to 2019 and will include the outstanding paragraphs of the Schedule covering payment notices and appeals against assessments.

Original consultation

Summary

The circumstances in which royalties and other types of payment made to connected persons not resident in the UK have a liability to Income Tax.

This consultation ran from
1pm on 1 December 2017 to 11:45pm on 23 February 2018

Consultation description

The government will introduce legislation in Finance Bill 2018 to 2019 that broadens the circumstances in which certain payments made to non-UK residents have a liability to Income Tax. These changes will take effect from April 2019.

The consultation focuses on the design of that legislation.

Documents

Royalties Withholding Tax - consultation

PDF, 304KB, 21 pages

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Published 1 December 2017
Last updated 24 May 2019 + show all updates

1. 24 May 2019

   Added note to outcome summary to explain that information is out of date, and link to a new consultation on legislation for Offshore Receipts in respect of Intangible Property.

2. 29 October 2018

   Summary of responses published, along with draft legislation, and an explanatory note.

3. 1 December 2017

   First published.