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Repeal of ORIP rules after 31 December 2024

At Autumn Statement 2023, the Government confirmed that the offshore receipts in respect of intangible property (ORIP) rules would be abolished for income arising after 31 December 2024. The repeal of the ORIP rules is introduced by Tolley's Finance Bill Tracking Service, Finance Bill 2025, cl 20, which completely removes the body of legislation on ORIP in ITTOIA 2005, Part 5 by omitting Chapter 2A. The repeal is taking place alongside the introduction of the undertaxed profits rule (UTPR) (by Tolley’s Finance Bill Tracking Service, Finance Bill 2025, cl 19), one of two charging mechanisms within the multinational top-up tax regime (see the Pillar Two ― overview of the UK’s multinational top-up tax guidance note), which is expected to comprehensively discourage the multinational tax planning arrangements that the ORIP regime sought to counter.

Entities within the scope of the ORIP rules for the 2024/25 income tax period are only required to report UK derived amounts arising prior to 31 December 2024.

A number of consequential