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

Section 608F: disregard for third party sales where intangible property makes insignificant contribution

Section 608GA provides that certain UK-derived amounts should be disregarded where intangible property rights make only an insignificant contribution to UK sales made by third parties.

• Where a person (A) receives or is entitled to a UK-derived amount, but the underlying goods, services or other property are not provided in the UK or to UK-based persons by A or anyone connected to A, the amount may be disregarded.
• The disregard applies only where the relevant intangible property rights enable, facilitate or promote the UK sales in question to an insignificant extent.
• When assessing whether A or a connected person provides goods in the UK, any goods supplied by a reseller are treated as provided by the person who originally supplied them to the reseller.
• A "reseller" is a person to whom goods or other property are provided for resale, as defined by section 608F(5).