The new Offshore Receipts rules will have effect from 6 April 2019 and include a TAAR applicable to arrangements put in place from 29 October 2018.
The draft legislation is included in Schedule 3 to the Finance Bill.
In overview, there will be an income tax charge:
This wording would appear sufficiently broad to catch receipts paid under almost any licence but not outright sales of IP or pre-existing licences
Important changes from the December 2017 condoc are:
