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HMRC internal manual

International Manual

DT applications and claims - Types of income: Royalties

Theatre backers - Angels

Payments made to non-resident theatre backers of plays and musicals (also known as “angels”) are in return for money put up by them in the finance of a production. If the show is successful their investment is first repaid and then they receive a share in any profit.

These payments are “annual payments” under Case III of Schedule D with tax deductible under ICTA88/S349. Relief from UK tax is available under the “Other Income” article (if there is one) and not the royalties article. In cases of doubt you should consider asking the claimant the question “Are you a theatrical angel who has provided financial backing for a theatrical production and is then entitled to a share of the profits?”

See BIM66601.