Income Tax (Trading and Other Income) Act 2005 section 608F

Meaning of "UK-derived amount" and "UK sales"

Section 608F defines what counts as a "UK-derived amount" and what constitutes "UK sales" for the purposes of the offshore receipts in respect of intangible property rules.

• A UK-derived amount is any sum connected to the use or exercise of rights over intangible property that directly or indirectly enables, facilitates or promotes UK sales
• UK sales cover goods, services or other property provided in the UK or to persons in the UK, but exclude anything provided for the purpose of resale
• Something is treated as "for resale" only if it is passed on to another person without alteration, with any differences being merely incidental to the provision of the item itself
• Online advertising services count as UK sales where the advertising is targeted at individuals located in the United Kingdom