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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Taiwan: Royalties

The Taiwanese tax deducted from royalties at the agreement rate of 10 per cent qualifies for credit as a direct tax.

The reduction to the above rate is not given if the interest is effectively connected (see INTM153110fifth sub-paragraph) with a business carried on by the United Kingdom resident recipient through a permanent establishment in Taiwan or with a fixed base in Taiwan from which they perform professional services.