Multinational Companies: Taxation

(asked on 24th April 2019) - View Source

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, pursuant to the Answer of 23 April 2019 to Question 242951 on Multinational Companies: Taxation, if he will publish each country that the HM Treasury considers to be a low-tax jurisdiction with which the UK does not have a full tax treaty for which offshore receipts in relation to the intangible property measure in the Finance Act 2019 will be applicable.


Answered by
Mel Stride Portrait
Mel Stride
Secretary of State for Work and Pensions
This question was answered on 29th April 2019

The Offshore receipts in respect of intangible property measure applies to entities that are not resident either in the UK, or in a jurisdiction with which the UK has a full tax treaty, meaning a tax treaty containing an appropriate non-discrimination article.

The measure only applies where the tax paid in the local territory on the relevant intangible property income is less than 50% of the charge that would otherwise arise under the measure. This tax rate test applies on an entity-by-entity basis, rather than at the level of the jurisdiction.

The measure may also apply to entities that are resident in territories where those entities are liable to tax on a territorial basis, subject to the UK’s treaty obligations and the tax rate test.

A list of jurisdictions with which the UK has a full tax treaty can be found here: https://www.gov.uk/hmrc-internal-manuals/international-manual/intm412090.

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