Commentary

A4.454 Payment of royalties without deduction of tax

Administration and compliance

A4.454 Payment of royalties without deduction of tax

A4.454 Payment of royalties without deduction of tax

Prior to 1 June 2021, a company paying royalties which would normally require income tax to be deducted under ITA 2007, ss 903(7), 906 (see A4.435, A4.441), was able to make the payment without deduction of income tax if, at the time of the payment, the company considered that conditions (A)–(C) in A4.451 were satisfied1.

However, from 1 June 2021, royalty payments made from the UK to a connected EU company are no longer automatically paid without deduction of withholding tax2. The UK domestic legislation that gave effect to the EU Interest and

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