INTM342580 - DT applications and claims - Types of income: Royalties
Theatre backers - Angels
Payments made to non-resident theatre backers of plays and musicals (also known as 鈥渁ngels鈥�) are in return for money put up by them in the finance of a production. If the show is successful their investment is first repaid and then they receive a share in any profit.
These payments are 鈥渁nnual payments鈥� under Case III of Schedule D with tax deductible under ICTA88/S349. Relief from UK tax is available under the 鈥淥ther Income鈥� article (if there is one) and not the royalties article. In cases of doubt you should consider asking the claimant the question 鈥淎re you a theatrical angel who has provided financial backing for a theatrical production and is then entitled to a share of the profits?鈥�
See BIM66601.