Overseas royalties and other income from intangibles

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Corporation Tax

Guidance

Where a UK company receives royalties, the company may suffer withholding tax in the jurisdiction where the payments are made. The level of withholding tax will depend on the jurisdiction (eg the Netherlands has no withholding tax on royalties, regardless of the country to which they are paid) and whether or not there is a tax treaty between the UK and that country. Tax treaties will reduce royalty withholding taxes substantially, often to nil. A claim for treaty benefit will be required to ensure the payment of royalties is made with no / reduced withholding as appropriate. For payments made before 1 January 2021, withholding tax on payments of royalties to a UK company may also be eliminated under the Interest

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Anne Fairpo

Barrister

With effect from 1 June 2021, Anne Fairpo is a judge of the First-tier Tribunal sitting in the Tax Chamber. She was previously a fee-paid judge in the same Chamber. Her contributions to LexisPSL Tax and TolleyGuidance were written before her full-time appointment and are her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary. Until April 2021, Anne was a tenant at Temple Tax Chambers. She was called to the bar in 2009 after 15 years as a solicitor. Anne’s experience and expertise covers UK and international corporate tax planning and disputes, having acted for a range of clients from small owner-managed businesses to listed multinationals, as well as having advised on intellectual property taxation and UK-US cross-border tax planning, with regard to both direct and indirect tax matters

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