Repeal of the Offshore Receipts in Respect of Intangible Property (ORIP) rules
This tax information and impact note describes the amendments being made to repeal the ORIP rules.
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This measure repeals the offshore receipts in respect of intangible property (ORIP) rules at Chapter 2A of Part 5 Income Tax (Trading and Other Income) Act 2005.
The offshore receipts in respect of intangible property legislation is no longer required because the Organisation for Economic Co-operation and Development (OECD) and G20 Inclusive Framework’s Pillar 2 global minimum tax will more effectively address the multinational tax-planning arrangements that offshore receipts in respect of intangible property sought to counter. The repeal will take place alongside the introduction of Pillar 2’s undertaxed profits rule in the UK from 31 December 2024.