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

Corporation Tax

Real estate investment trusts (REITs)

Real estate investment trusts (REITs)Introduction to REITsA real estate investment trust (REIT) is in fact not a trust at all, it is a company which qualifies for special tax treatment under CTA 2010, Part 12. REITs are similar in many ways to collective fund vehicles (such as unit trusts) in that

14 Jul 2020 13:04 | Produced by Tolley in association with Rob Durrant-Walker of Crane Dale Tax, part of AMS Group Read more

Value Added Tax

Reverse charge ― buying in services from outside the UK

Reverse charge ― buying in services from outside the UKThis guidance note covers the reverse charge that applies to services that have been bought in from outside the UK. For an overview of VAT and international services more broadly, see the International services ― overview guidance note. For

15 Dec 2020 14:02 | Produced by Tolley Read more

Corporation Tax

Corporate interest restriction ― administrative aspects

Corporate interest restriction ― administrative aspectsThe corporate interest restriction (CIR) regime has some specific administrative rules in addition to the general administrative requirements for corporation tax returns. This guidance note does not include commentary on provisions that are

14 Jul 2020 11:19 | Produced by Tolley Read more

UU��ֱ��