Corporation Tax

Offshore receipts in respect of intangible property

Produced by Tolley
  • 23 Mar 2022 10:38

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Offshore receipts in respect of intangible property
  • Offshore receipts on intangibles: amounts assessed
  • Exemptions to charge on offshore receipts from intangibles

Offshore receipts in respect of intangible property

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. 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. HMRC issued final regulations (SI 2019/1452) on 4 November 2019 amending the legislation. HMRC guidance can be found at INTM620000 onwards.

A full treaty territory is one where double tax arrangements have been made in relation to that territory which contains a non-discrimination clause. A non-discrimination provision arises where A and B have a double tax arrangement whereby a national of state A is not subject to any taxation (or any requirement connected with taxation) in state B which is more burdensome than the same taxation or requirements of a national of state B in the same circumstances.

A detailed description of the rules can be found in Simon’s Taxes D4.122A and the rules are discussed further in ‘The new income tax charge on offshore receipts in respect of intangibles’ by Dominic Robertson and Steve Edge in Tax Journal, Issue 1423, 8 (30 November 2018).

Offshore receipts on intangibles: amounts

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