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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Georgia: Royalties

Royalties arising in Georgia and paid to a resident of the UK who is the beneficial owner of the royalties are exempt from tax in Georgia (Article 12(1)).

Where, however, the royalties are effectively connected with a permanent establishment which the UK resident recipient has in Georgia, the provisions of the Business Profits Article (Article 7) will apply.