PwC took part in discussions with HMRC following the publication of the new Offshore Receipts in respect of Intangible Property legislation at Budget 2018. Following that meeting, HMRC has provided an update regarding plans to introduce regulations to refine the offshore receipts regime.
It is intended that regulations will be published in draft, for consultation, prior to 6 April. In line with expectations, the regulations will include provisions to:
- ensure that transfers of IP to the UK should not generally trigger the TAAR;
- make clearer how to link UK sales and income in charge (e.g. whether to look through to UK end customers or whether to build in sales to UK master distributors in certain cases); and
- respond to concerns that companies in certain high tax regimes may be in charge.
For further information, please contact Adrian Gregory or your usual PwC adviser.
