The government has published the final draft of regulations making technical amendments to the rules for offshore receipts in respect of intangible property (ORIP) introduced by Finance Act 2019. These rules tax income generated by multinational groups from intellectual property held in low-tax jurisdictions, to the extent that income is referable to UK sales.
The draft Income Tax (Trading and Other Income) Act 2005 (Amendments to Chapter 2A of Part 5) Regulations 2019 include amendments to:
Most of the relieving amendments will have effect from 6 April 2019, with the remainder applying only to amounts arising after the regulations are made.
HMRC has also published a tax information and impact note outlining the amendments, which follow consultation on an initial draft of the regulations between May and July. HMRC has also updated its draft technical guidance on the ORIP rules, which will form new ‘International manual’ chapter INTM870000.
See bit.ly/2VVxLn5.
The government has published the final draft of regulations making technical amendments to the rules for offshore receipts in respect of intangible property (ORIP) introduced by Finance Act 2019. These rules tax income generated by multinational groups from intellectual property held in low-tax jurisdictions, to the extent that income is referable to UK sales.
The draft Income Tax (Trading and Other Income) Act 2005 (Amendments to Chapter 2A of Part 5) Regulations 2019 include amendments to:
Most of the relieving amendments will have effect from 6 April 2019, with the remainder applying only to amounts arising after the regulations are made.
HMRC has also published a tax information and impact note outlining the amendments, which follow consultation on an initial draft of the regulations between May and July. HMRC has also updated its draft technical guidance on the ORIP rules, which will form new ‘International manual’ chapter INTM870000.
See bit.ly/2VVxLn5.