UK HMRC Repeal of ORIP Rules


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.
  • Follows, UK Treasury Oct. 2024 details of the autumn budget 2024, see #231484.
  • 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.

Regulators UK Treasury
Entity Types Corp
Reference Nt, PR 10/30/2024; IT(TOI)A 2005 (UK)
Functions Financial; Legal; Operations; Reporting; Tax
Countries United Kingdom
Category
State
Products Corporate
Regions EMEA
Rule Type Final
Rule Date 10/30/2024
Effective Date 12/31/2024
Rule Id 234633
Linked to Rule :231484
Reg. Last Update 10/30/2024
Report Section UK

Last substantive update on 11/28/2024