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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Armenia: royalties

Where the beneficial owner of the royalties is a resident of the United Kingdom, a reduced rate of 5% withholding tax is payable.

The reduced rate provided by the treaty is not given if the royalty is effectively connected (see INTM153110 eighth sub-paragraph) with a permanent establishment which the United Kingdom resident recipient has in Armenia.