Offshore receipts in respect of intangible property

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Repeal of ORIP rules after 31 December 2024

At Autumn Statement 2023, the Government confirmed that the offshore receipts in respect of intangible property (ORIP) rules would be abolished for income arising after 31 December 2024. The repeal of the ORIP rules was introduced by Finance Act 2025, s 20, which completely removed the body of legislation on ORIP in ITTOIA 2005, Part 5 by omitting Chapter 2A. The repeal took place alongside the introduction of the undertaxed profits rule (UTPR) (by Finance Act 2025, s 19), one of two charging mechanisms within the multinational top-up tax regime (see the Pillar Two ― overview of the UK’s multinational top-up tax guidance note), which is expected to comprehensively discourage the multinational tax planning arrangements that the ORIP regime sought to counter.

Entities within the scope of the ORIP rules for the 2024/25 income tax period are only required to report UK derived amounts arising prior to 31 December 2024.

A number of consequential amendments to other legislative provisions are also required in order to remove

Continue reading the full document

To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™

TAKE A FREE TRIAL NOW

Popular Articles

Personal Tax

Income tax losses ― overview

Income tax losses ― overviewIncome tax losses can arise due to a number of reasons, but not all losses can be relieved against total income and some losses can only be set against certain types of component income. The table below is a summary of the main reliefs for income tax losses.Summary of

04 Mar 2021 12:19 | Produced by Tolley Read more

Owner-Managed Businesses

Class 4 national insurance contributions

Class 4 national insurance contributionsWhat is Class 4 NIC?Class 2 and Class 4 national insurance contributions (NIC) are paid by self-employed individuals and partners in a partnership on their profits arising within the UK. This guidance note considers Class 4 contributions. For Class 2

14 Jul 2020 11:13 | Produced by Tolley Read more

Personal Tax

Self assessment ― estimates and provisional figures

Self assessment ― estimates and provisional figuresIf the taxpayer does not have sufficient information to enable them to complete the tax return in the time allowed, they should include either a best estimate or a provisional figure. The taxpayer should not either leave a box blank or enter

14 Jul 2020 13:37 | Produced by Tolley Read more

��Ƶ