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ITA and Royalties

Mathew Oliver Tax Partner and Ingrid Toth Tax Associate Bird & Bird consider the changes to the deduction of tax at source rules for royalties
The Income Tax Act 2007 (ITA) undertook a radical rewrite of the rules relating to deduction of tax at source. Whereas the rules were previously spread over a few discrete sections of the legislation they are now contained in over 100 sections of the ITA (not taking into account the rewrite of the administration rules).
Approaching the new rules for the first time is a daunting task for even the hardiest adviser. The purpose of this article is to look at one small part of the new rules: how they apply to royalty payments in respect of intellectual property (IP).

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