UK resident company pays royalties to non-UK resident company. Deduction of basic rate tax applies, but a lower "treaty rate" may be used under S911 ITA2007.
In this case, the UK company is paying a US company. What is the Treaty Rate between the UK and USA please? Can't find it anywhere! HMRC say it is 10% but I need to check.
Thanks.
Colin
Replies (4)
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there are a number of interesting points here
where did the income in question arise
where is the author or rights holder resident
what type of income is it
why no application for no withholding tax
Here...
... is a better link:
http://www.hmrc.gov.uk/pdfs/ukusa_dtconvention.pdf
See paragraph 1 of Article 12 for zero rate on Royalties
Thanks Ebeneezer, but......
I can't find any reference to either 0% or 10%. Can you point me in the specific right direction please? Thanks.
Check...
...here:
http://www.ustreas.gov/offices/tax-policy/library/uktreaty.pdf.
Seems to say the US/UK Treaty rate on Royalties and Interest is 0%, not 10%.