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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.