On Oct. 30, UK HMRC issued measure re offshore asset tax measures.
UK HMRC issued tax information and impact note describing amendments being made to repeal the Offshore Receipts in Respect of Intangible Property (ORIP) rules.
Document dated Oct. 30, 2024, was received on Nov. 27, 2024 due to a fixed feed.
Details
This measure repeals the offshore receipts in respect of intangible property (ORIP) rules at part 5, chapter 2A Income Tax (Trading and Other Income) Act 2005.
ORIP legislation is no longer required because OECD and G20 Inclusive Framework’s Pillar 2 global minimum tax will more effectively address the multinational tax-planning arrangements that offshore receipts regarding intangible property sought to counter.
Effectiveness
Repeal takes place alongside introduction of Pillar 2’s undertaxed profits rule in UK from Dec. 31, 2024.