41 Deduction of income tax at source: intellectual property - tax avoidance
Finance Act 2016 (2016 c 24) | Legislation

41  Deduction of income tax at source: intellectual property - tax avoidance

(1)     In Part 15 of ITA 2007 (deduction of income tax at source), after section 917 insert—

“Tax avoidance

917A Tax avoidance arrangements

(1)     This section applies if and to the extent that—

(a)     a person (“the payer”) makes an intellectual property royalty payment,

(b)     the payment is received by a person (“the payee”) who is connected with the payer, and

(c)     the payment is made under DTA tax avoidance arrangements.

(2)     Any duty under Chapter 6 or 7 to deduct a sum representing income tax at any rate applies without regard to any double taxation arrangements.

(3)     Any income tax deducted by virtue of subsection (2) may not be set off under section 967 or 968 of CTA

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