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<p>The scope of the legislation “Offshore Receipts in respect of Intangible Property”
is limited to territories with which the UK does not have a full tax treaty. A “full
treaty territory” is defined in the legislation as a treaty containing a non-discrimination
provision. A non-discrimination provision is defined by reference to nationals of
a state. Jersey, Guernsey and the Isle of Man are not “states”, they are territories
for which the UK is responsible and so cannot meet that condition.</p><p> </p><p>It
follows that the Crown Dependencies are within scope of the legislation. The government
has committed to respecting its international obligations in respect of this measure.
As such the provisions of the relevant treaties will apply to any arrangements involving
the Crown Dependencies that are subject to the legislation, and the UK will provide
for treaty relief where applicable.</p>
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