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<p>The taxation of offshore receipts in respect of intangible property was a new measure
enacted in Section 15 of and Schedule 3 to the Finance Act 2019. The measure applies
a direct UK Income tax charge to amounts received in a low tax jurisdiction in respect
of intangible property, to the extent that those amounts are referable to the sale
of goods or services in the UK. It is forecast to raise over £1.1 billion over five
years, as follows:</p><p> </p><p>Exchequer impact (£m)</p><table><tbody><tr><td><p>2018
to 2019</p></td><td><p>2019 to 2020</p></td><td><p>2020 to 2021</p></td><td><p>2021
to 2022</p></td><td><p>2022 to 2023</p></td><td><p>2023 to 2024</p></td></tr><tr><td><p>0</p></td><td><p>0</p></td><td><p>+475</p></td><td><p>+275</p></td><td><p>+220</p></td><td><p>+165</p></td></tr></tbody></table><p>
</p><p>The measure, as enacted, includes three exemptions: a de minimis of £10m of
UK sales, an exemption for business undertaken in the territory of residence, and
an exemption where tax is being charged at 50% or more of the UK tax. These exemptions
aim to target the legislation at multinational groups which generate significant income
from intangible property through UK sales and which have made arrangements such that
the income is received in offshore jurisdictions where it is taxed at no or low effective
rates. The yield forecast for the measure was based on the rules as defined in the
legislation.</p>
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