- Finance Bill 2019—income tax charge to extend to offshore receipts in respect of intangible property
- Original news
- What and who are the offshore receipts rules aimed at and when do they take effect?
- When do the rules take effect?
- What are the exemptions?
- Foreign tax at least half of UK tax
- Business undertaken in the non-UK territory
- Limited UK sales
- The government originally intended to extend the provisions on royalty withholding tax, but at Budget 2018, the government announced that it was instead introducing the rules on offshore receipts in respect of intangible property. What were the reasons behind this change?
- Anti-forestalling provisions apply from 29 October 2018—in which circumstances do they apply?
- How can taxpayers determine what amount is subject to charge?
- Given that the income tax charge on UK-derived amounts in respect of intangible property is charged directly on the non-UK resident, how is the government intending to enforce and collect this?
- What key changes were made to the draft legislation published on 7 November 2018 when compared to the previous version published on 29 October?
Tax analysis: The extension of the provisions on royalty withholding tax contained in the Autumn Budget 2017 has re-emerged in the Budget 2018, as new rules on offshore receipts in respect of intangible property. Zoe Feller, partner, and Andrew Rink, associate, at Bird & Bird, consider the draft legislation and explain the reasons behind the government’s redesign.
Sign in or take a trial to read the full analysis.
To continue reading this news article, as well as thousands of others like it, sign in to LexisPSL or register for a free trial