132 Interpreting provision about royalties influenced by special relationship
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

132  Interpreting provision about royalties influenced by special relationship

(1)     Subsection (3) and section 133 apply if double taxation arrangements—

(a)     make provision, whether for relief or otherwise, in relation to royalties (as defined in the arrangements), and

(b)     contain a special relationship rule.

(2)     A “special relationship rule” is provision that—

(a)     applies if the amount of the royalties paid is, because of a special relationship, greater than the amount (“the ordinary amount”) that would have been paid in the absence of the relationship, and

(b)     has the effect that the provision mentioned in subsection (1)(a) is to apply only to the ordinary amount.

(3)     The special relationship rule is to be read as requiring account to be taken of all factors, including—

(a)     the question

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