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Legislation
Finance Act 2025

Crossheading International matters

  • Section 19 Pillar Two
  • Section 20 Offshore receipts in respect of intangible property
  • Section 21 Application of PAYE in relation to internationally mobile employees etc.
  • Section 22 Advance pricing agreements: indirect participation in financing cases
  1. International matters
  2. Offshore receipts in respect of intangible property

Section 20 | Offshore receipts in respect of intangible property

From legislation.gov.uk

(1)ITTOIA 2005 is amended as follows.

(2)In section 574 (overview of Part 5)—

(a)in subsection (1) omit paragraph (aa);

(b)in subsection (2) omit “(but see section 608X)”.

(3)Omit Chapter 2A (offshore receipts in respect of intangible property) of Part 5.

(4)In section 576 (priority between Chapters within Part 5) omit subsection (1).

(5)In section 873(3) (procedure for orders and regulations) omit paragraph (ba).

(6)TIOPA 2010 is amended as follows.

(7)In section 157(1) (direct participation)—

(a)at the end of paragraph (d) insert “, and”;

(b)omit paragraph (f) and the “and” preceding it.

(8)In section 159(1) (indirect participation: potential direct participant)—

(a)at the end of paragraph (d) insert “, and”;

(b)omit paragraph (f) and the “and” preceding it.

(9)In section 160(1) (indirect participation: one of several major participants) omit paragraph (f) and the “and” preceding it.

(10)In consequence of subsections (1) to (9), omit Schedule 3 to FA 2019 (offshore receipts in respect of intangible property).

(11)Omit section 981A of ITA 2007 (offshore receipts in respect of intangible property: exception from duties to deduct).

(12)The amendments made by this section have effect in relation to income arising on or after 31 December 2024.

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