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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Guidance by country: Bahrain: royalties

Royalties are taxable only in the state of residence of the beneficial owner of the royalties unless the right or property in respect of which the royalties are paid is effectively connected with a permanent establishment in the source state. In the latter circumstances, the provisions of the Business profits Article (Article 7) will apply.