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HMRC internal manual

Double Taxation Relief Manual

Moldova: Royalties

Royalties arising in Moldova and paid to a resident of the United Kingdom who is the beneficial owner of the royalties are taxable in Moldova at a rate not exceeding 5 per cent Article 12(2)).

Where, however, the royalties are effectively connected with a permanent establishment which the United Kingdom resident recipient has in Moldova, the provisions of the Business Profits Article (Article 7) will apply.