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Part 5U.K.Miscellaneous income

[F1CHAPTER 2AU.K.Offshore receipts in respect of intangible property

Textual Amendments

F1Pt. 5 Ch. 2A inserted (with effect in accordance with Sch. 3 para. 7 of the amending Act) by Finance Act 2019 (c. 1), Sch. 3 para. 4 (with Sch. 3 para. 8)

Modifications etc. (not altering text)

C1Pt. 5 Ch. 2A: power to amend conferred (with effect in accordance with Sch. 3 para. 7 of the amending Act) by Finance Act 2019 (c. 1), Sch. 3 para. 10

Charge to tax on offshore receipts in respect of intangible propertyU.K.

608EMeaning of “full treaty territory”U.K.

(1)For the purposes of this Chapter a territory is a “full treaty territory” if—

(a)double taxation arrangements have been made in relation to the territory, and

(b)the arrangements contain a non-discrimination provision.

(2)In subsection (1) “non-discrimination provision”, in relation to double taxation arrangements, means a provision to the effect that nationals of a state which is a party to those arrangements (a “contracting state”) are not to be subject in the other contracting state to—

(a)any taxation, or

(b)any requirement connected with taxation,

which is other or more burdensome than the taxation and connected requirements to which nationals of that other contracting state in the same circumstances (in particular with respect to residence) are or may be subjected.

(3)In subsection (2) “national”, in relation to a contracting state, includes—

(a)an individual possessing the nationality or citizenship of the contracting state, and

(b)a legal person, partnership or association deriving its status as such from the laws in force in that contracting state.]