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Chapter DT20711

Document Cited in Related
Vincent
Published date20 May 2016
Record NumberDT20711
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

(1) Royalties arising in a Contracting State which are derived and beneficially owned by a resident of the other Contracting State may be taxed in that other State.

(2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the law of that State, but the tax so charged shall not exceed 10 percent of the gross amount of the royalties.

(3) The term `royalties` as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade mark, design or model, plan, secret formula or process,or for the use of, or the right to use, industrial, commercial or scientific equipment, orfor information concerning industrial, commercial or scientific experience.

(4) The provisions of paragraphs (1) and (2) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State has in the other Contracting State in which the royalties arise a permanent establishment with which the right or property giving rise to the royalties is effectively connected. In such acase, the provisions of Article 7 shall apply.

(5) Royalties shall be deemed to arise in...

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