INTM620450 - Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Payment

ITTOIA05/Ch2A/S608R

Relevant person’s right to reimbursement

A relevant person who receives a notice under section 608O and subsequently pays any tax and/or interest may recover that sum from the taxpayer to whom the original assessment was sent.

Any reimbursement of such a payment will not be treated as a receipt nor any payment allowed as a deduction in calculating the relevant person’s income, profits or losses for any tax purposes.

Payment of liability

A notice may be issued to more than one relevant person so long as the necessary conditions are met (see INTM620410). Once either the taxpayer or relevant person has paid any tax and/or interest, all parties liable are treated as having met their liabilities up to the amount of tax and/or interest paid.