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FB 2016: Withholding tax on royalties

The changes in the current Finance Bill will bring rather more intellectual property royalties into the scope of withholding tax, as Anne Fairpo (Temple Tax Chambers) explains.
 
The UK’s approach to withholding tax in domestic law has historically been rather haphazard: withholding tax has been applied only to certain limited types of intellectual property and to certain types of intellectual property payments. The rules were inconsistent and not particularly intelligible.
 
The changes in the current Finance Bill will bring rather more intellectual property royalties into the scope of withholding tax although that broadening may simplify the rules for UK payers of royalties by removing some of the uncertainties as to what is or is not within the scope of withholding tax.
 
However the broadening of the rules also means that it...

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