Jurisdiction(s):
United Kingdom

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Key definition

Territory definition

What does Territory mean? In practice, Territory describes the geographical area in or for which the contract grants rights, imposes obligations or restricts activities (for example, in IP licences, distribution, agency and franchise agreements). It is a descriptive contractual term, not generally defined by legislation or case law, but its scope engages competition and antitrust rules and sanctions/export controls. Usage is broadly consistent across England and Wales, Scotland, Northern Ireland and Ireland. Draft precisely: Great Britain (England, Wales and Scotland) is not the same as the United Kingdom (Great Britain and Northern Ireland); Ireland refers to the state; the island of Ireland comprises Ireland and...

UK ORIP (offshore receipts from intangible property) 6 Apr 2019-30 Dec 2024: legislation, scope, exemptions, TAAR, de minimis, partnerships, administration, self-assessment and recovery; abolished by FA 2025 - archived

Published by a LexisNexis Tax expert

Practice notes

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Section 20 of the Finance Act 2025 (FA 2025) repealed the offshore receipts in respect of intangible property (ORIP) regime for amounts accruing on or after 31 December 2024.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 The regime was withdrawn on the basis that the undertaxed profits rule (UTPR), which came into force in the UK on 31 December 2024, is expected to provide a more comprehensive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...

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Web page updated on 22/05/2026

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