Commentary

B5.319 Payment of royalties without deduction of tax

Business tax
Business tax | Commentary

B5.319 Payment of royalties without deduction of tax

Business tax | Commentary

B5.319 Payment of royalties without deduction of tax

For the latest New Development, see ND.1438.

A UK company is normally required to deduct income tax at the basic rate when making a payment of interest or royalty, and to account to HMRC1 for the tax deducted.

UK withholding tax may be reduced under double tax treaties (DTT) or (for payments made before 1 June 2021) European directives, both of which may be subject to making a formal claim. Draft legislation is included within Finance Bill 2021 which proposes to repeal the UK domestic legislation that gave effect to this exemption from withholding

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