Gross receipts meaning

ARCHIVED : Section 20 of the Finance Act 2025 (FA 2025) repealed the offshore receipts in respect of intangible property (ORIP) regime for amounts accruing on or after 31 December 2024. Accordingly, ORIP is relevant only to receipts arising from 6 April 2019 through to and including 30 December 2024. The regime was withdrawn on the basis that the undertaxed profits rule (UTPR), which came into force in the UK on 31 December 2024, is expected to provide a more comprehensive deterrent to the multinational tax-planning arrangements that ORIP was designed to tackle. HMRC’s guidance at INTM620710 confirms that, for the 2024–25 tax year, entities within ORIP’s scope need only report ‘UK-derived amounts’ arising before 31 December 2024. For further detail on the UTPR, see: Multinational top-up tax and domestic top–up tax—overview...

For an interest in possession beneficiary, the trust works as a channel through which income flows, keeping its nature and tax treatment for tax purposes. Interest arrives gross; tax is settled by the trustees and appears as net interest for the life tenant in their hands. Likewise, dividends come in gross and the trustees pay the tax, unless the income is mandated directly to the life tenant. This ‘look‑through’ approach acknowledges that the beneficiary is entitled to income as it arises. By contrast, a discretionary beneficiary has no entitlement to the trust’s income until the trustees choose to distribute it. There is no prescribed mechanism to align a payment with income received by the trustees in any period. Therefore, the beneficiary cannot ‘look through’ the trust to the original source of that income. The same applies where the trustees simply hold a power to accumulate income instead of paying it out, even if that power is not exercised. When income is paid to a beneficiary whose entitlement depends on the...