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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Double Taxation Relief Manual: Guidance by country: Argentina: Royalties

Royalties arising in Argentina and paid to a resident of the United Kingdom who is the beneficial owner of the royalties are taxable in Argentina at a rate not exceeding:

  • 3 per cent for the use of, or the right to use, news
  • 5 per cent for the use of copyright of literary, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films and works on film or videotape or other means of reproduction for use in connection with television) but only if the royalties are derived by the author himself or his descendants
  • 10 per cent for the use of any patent, trademark, design or model, plan, secret formula or process, or for the use of industrial or scientific equipment, or for information concerning industrial or scientific experience, or for the rendering of technical assistance (after deduction of expenses directly related to the provision of the technical assistance)
  • 15 per cent in all other cases (Article 12(2).

Where, however, the royalty is effectively connected with a permanent establishment or fixed base which the United Kingdom resident recipient has in Argentina, the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14) will apply.