Jeremy Cape and Bernhard Gilbey (Squire Patton Boggs) examine recent consultation proposals that further expand the concept of ‘UK source’ for royalties.
Following the announcement in the Autumn Budget 2017 that the government intends to broaden the scope of withholding tax on royalties HM Treasury and HMRC published a consultation document on 1 December 2017 setting out how they might go about doing so.
The proposals outlined in the consultation document build further on the changes introduced in FA 2016 which were intended to ensure that royalties with a connection to the UK would be subject to deduction of tax at source unless the UK had explicitly given up its taxing rights under a double tax agreement (DTA). These changes have not however been entirely successful.
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Jeremy Cape and Bernhard Gilbey (Squire Patton Boggs) examine recent consultation proposals that further expand the concept of ‘UK source’ for royalties.
Following the announcement in the Autumn Budget 2017 that the government intends to broaden the scope of withholding tax on royalties HM Treasury and HMRC published a consultation document on 1 December 2017 setting out how they might go about doing so.
The proposals outlined in the consultation document build further on the changes introduced in FA 2016 which were intended to ensure that royalties with a connection to the UK would be subject to deduction of tax at source unless the UK had explicitly given up its taxing rights under a double tax agreement (DTA). These changes have not however been entirely successful.
Existing...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
