Offshore receipts in respect of intangible property (ORIP)

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Offshore receipts on intangibles ― overview

From the tax year 2019/20, an income tax charge is applied to certain receipts of non-UK resident persons who are not resident in a full treaty territory, which are in respect of intangible property. A full treaty territory is one with which the UK has a double tax treaty that contains a non-discrimination article. The charge is calculated by reference to the extent to which such receipts are referable to the sale of goods or services in the UK. These rules are known as the offshore receipts in respect of intangible property (ORIP) rules and the aim of the legislation is to discourage multinational groups from placing intangible property in low tax jurisdictions where the income will be subject to no or low tax.

HMRC guidance can be found at INTM620000 onwards. A more detailed description of the ORIP rules can be found in Simon’s Taxes D4.122A.

Future changes

Access this article and thousands of others like it
free for 7 days with a trial of TolleyGuidance.

TAKE A FREE TRIAL

Popular Articles

Personal Tax

Foreign tax relief

Foreign tax reliefIncome and gains may be taxable in more than one country. The UK has three ways of ensuring that the individual does not bear a double burden:1)treaty tax relief may reduce or eliminate the double tax2)if there is no treaty, the individual can claim ‘unilateral’ relief by deducting

14 Jul 2020 11:44 | Produced by Tolley Read more

Tax Returns

Owner-Managed Businesses

Interest on late paid tax

Interest on late paid taxIntroductionInterest on late paid tax is a compulsory charge set out in legislation to reflect the interest which would have accrued to the Exchequer had the correct amount of tax been paid at the right time.Harmonised legislation was introduced in 2009 to:•set statutory

14 Jul 2020 12:00 | Produced by Tolley in association with Philip Rutherford Read more

Trusts and Inheritance Tax

Bare trusts ― income tax and CGT

Bare trusts ― income tax and CGTThis guidance note explains how trustees of bare trusts are treated for income tax and capital gains purposes. Although a bare trust is, in equity, a type of trust, for both income tax and capital gains tax purposes its existence is transparent. This means that no tax

14 Jul 2020 15:34 | Produced by Tolley Read more

UU��ֱ��