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HMRC internal manual

Double Taxation Relief Manual

Non-residents: UK income: Returns and reports: Enquiries by FICO - beneficial ownership

Although generally for the agreement to apply the royalty recipient must be the beneficial owner of the royalties, some older agreements have a subject to tax condition in place of the beneficial ownership criterion which requires the claimant to be subject to tax on the royalties in their country of residence (see DT802). Overseas royalty agents who act as royalty `collectors’ will often not be beneficial owners of the royalties or subject to tax on them.