INTM620520 - Offshore Receipts in respect of Intangible Property (ORIP): General: Interaction with other provisions

ITTOIA05/Ch2A/S608X

When s608A applies, or would apply, to a person for a tax year, Chapter 1 of Part 14 ITA07 will not apply to that person’s UK-derived amounts arising in that tax year. Broadly, Chapter 1 of Part 14 ITA07 provides limits on the liability to income tax of non-UK residents.

A person’s liability, when s608A applies, will therefore be the sum of their liability from UK- derived amounts (with Chapter 1 of Part 14 ITA07 not applying), and their liability as regards anything else (with Chapter 1 of Part 14 ITA07 applying as usual).

ITA07/S981A

A consequential amendment inserted into Part 15 of ITA07 is the new s981A, which has the effect of switching off the normal withholding obligation of Part 15 from payments charged to income tax under ITTOIA05/Ch2A. Should withholding be suffered in addition to ORIP on amounts arising between 6 April 2019 and 5 November 2019, please contact Technical Queries, ORIP