On 14 October 2019, the government published a number of documents in response to its consultation on draft Regulations relating to offshore receipts in respect of intangible property.
The Offshore Receipts in respect of Intangible Property (ORIP) rules were introduced by section 15 of, and Schedule 3 to, Finance Act 2019. A tax information and impact note for the ORIP rules was published on 29 October 2018, which provides further details on the background to the regime.
As a result of consultation with affected businesses, advisory firms and representative bodies, certain technical amendments to the legislation have been identified that are necessary for the regime to work as intended.
The definition of UK sales has been clarified to make the rules more proportionate and improve their targeting and there are new rules to minimise double taxation, and better targeting of the jurisdictions in scope. HMRC has published the updated statutory instrument, explanatory memorandum and tax information and impact note.