INTM620210 - Offshore Receipts in respect of Intangible Property (ORIP): Charge to tax on ORIP: Charge to tax on UK-derived amounts

ITTOIA05/Ch2A/S608A, S608B and S608C

The charge to tax on UK-derived amounts applies if, at any time in the tax year, a person is not resident in the UK or a {full treaty territory

INTM620730}and {UK-derived amounts INTM620740} arise to them. Subject to some exemptions, income tax is chargeable on the full amount of the UK-derived amounts arising in the tax year. The person liable for the tax charge is the person receiving, or entitled to, the UK-derived amounts.

Example

Company A is based in the Cayman Islands throughout the 2020/21 tax year. Company A has UK-derived amounts of £30 million arising during that tax year. No exemptions apply to Company A and so Company A will be subject to income tax on the full £30 million.