B5.318 Cross border royalties
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, Chs 15) or ss 963, 963A (16) (see A4.465), and it reasonably believes, at the time the payment is made, that 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.
If, despite the company's belief, the payee was not, at the time of the payment, entitled to double taxation relief, the provision
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