Income Tax Act 2007 section 933

UK resident companies

Section 933 defines when a payment qualifies as an "excepted payment" because the beneficial recipient is a UK resident company.

• A payment is an excepted payment if the person beneficially entitled to the income is a UK resident company
• This is the first in a series of sections that set out the various categories of excepted payments
• The key test is beneficial entitlement — it is not enough for the company merely to receive the payment; it must be the true beneficial owner of the income
• Where a payment qualifies as an excepted payment, the payer is not required to deduct income tax at source before making the payment