INTM620795 - Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Other definitions

ITTOIA05/Ch2A/S608Z

This section provides definitions of terms used throughout the legislation.

Arrangements

Any type of agreement, understanding, scheme, and transaction. It does not matter if they are not legally enforceable.

The Commissioners

Commissioners for HM Revenue & Customs.

Control group

As defined in s608S (see INTM620760.)

Designer tax provisions

Provisions that appear to the Commissioners to be designed to enable persons to have a significant degree of control over the tax liability they have arising from UK-derived amounts.

Double taxation arrangements

Arrangements that have effect under section 2(1) TIOPA10.

Full treaty territory

As defined in s608E (see INTM620730)

Intangible property

As defined in s608H (see INTM620750)

As defined in s608T (see INTM620770)

Resident

As defined in s608D (see INTM620720)

Tax

Where used in this Chapter to refer to tax applied by territories outside the United Kingdom, this is a reference to a tax that is both charged on income, and which corresponds to income tax or corporation tax. Note that the tax may only be payable under the laws of a province or state, rather than a country, but the tax here is still held to correspond to income tax or corporation tax.

Tax advantage

As defined in s608W(5)

In this Chapter tax advantage includes:

  • relief or increased relief from tax,
  • repayment or increased repayment of tax,
  • avoidance or reduction of a charge to tax or an assessment to tax,
  • avoidance of a possible assessment to tax,
  • deferral of a payment of tax or advancement of a repayment of tax, and
  • avoidance of an obligation to deduct or account for tax.

UK-derived amount

As defined in s608F (see INTM620740)

UK Sales

As defined in s608F (see INTM620740)