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03 June 2019
HMRC has published draft regulations to amend the rules introduced by FA 2019 taxing income from intellectual property held by entities in low tax jurisdictions and used to support UK sales. These include amendments to:
- ensure the charge applies in jurisdictions where treaty relief is not available;
- modify the definition of ‘UK sales’ in relation to resellers and online advertising;
- introduce an exemption for companies in jurisdictions to be specified by regulations;
- ignore sales for which the intellectual property contribution is insignificant; and
- prevent double taxation of partnerships taxed in other jurisdictions and sub-licences granted to related entities.
Comments should be emailed by 19 July to withholding-tax.mailbox@hmrc.gsi.gov.uk.
Draft regulations: tinyurl.com/itdregsorip
