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HMRC internal manual

Double Taxation Relief Manual

Jordan: Royalties

Royalties arising in Jordan and paid to a resident of the United Kingdom who is the beneficial owner of the royalty are taxable in Jordan at a rate not exceeding 10 per cent (Article 12(2)).

However where the royalty is effectively connected (see INTM153110) with a permanent establishment or fixed base which the United Kingdom resident recipient has in Jordan, it is not taxable under Article 12. Instead, the provisions of the Business profits Article (Article 7) or the Independent personal services Article (Article 14) will apply (Article 12(5)).