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HMRC internal manual

Double Taxation Relief Manual

Slovenia - Royalties

Royalties arising in Slovenia and paid to a resident of the United Kingdom who is the beneficial owner of the royalties are taxable in Slovenia at a rate not exceeding 5%.

Where, however, the royalty is effectively connected (see INTM153110) with a permanent establishment which the United Kingdom resident recipient has in Slovenia, the provisions of the Business profits Article (Article 7) will apply.