Offshore receipts in respect of intangible property

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Repeal of ORIP rules after 31 December 2024

At Autumn Statement 2023, the Government confirmed that the offshore receipts in respect of intangible property (ORIP) rules would be abolished for income arising after 31 December 2024. The repeal of the ORIP rules was introduced by Finance Act 2025, s 20, which completely removed the body of legislation on ORIP in ITTOIA 2005, Part 5 by omitting Chapter 2A. The repeal took place alongside the introduction of the undertaxed profits rule (UTPR) (by Finance Act 2025, s 19), one of two charging mechanisms within the multinational top-up tax regime (see the Pillar Two ― overview of the UK’s multinational top-up tax guidance note), which is expected to comprehensively discourage the multinational tax planning arrangements that the ORIP regime sought to counter.

Entities within the scope of the ORIP rules for the 2024/25 income tax period are only required to report UK derived amounts arising prior to 31 December 2024.

A number of consequential amendments to other legislative provisions are also required in order to remove

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