Payments to an overseas company with a double tax agreement with the UK
A4.445 Cross border royalty payments
Where a company pays a royalty1 from which it is required to deduct tax which is collectible under ITA 2007, ss 945–962 (Pt 15, Ch 15) or ITA 2007, ss 963, 963A (Pt 15, Ch 16) (see A4.465), and it reasonably believes that at the time the payment is made, the payee2 is entitled to relief in respect of the payment under double taxation arrangements, the company may calculate the sum to be deducted by reference to the treaty rate3.
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial