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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Grenada: double taxation agreement, Article 7: Royalties

(1) Any royalty derived from sources within one of the territories by a resident of theother territory who is subject to tax in that other territory in respect thereof and isnot engaged in trade or business in the first-mentioned territory through a permanentestablishment situated therein, shall be exempt from tax in that first-mentionedterritory; but no exemption shall be allowed under this paragraph in respect of so much ofany royalty as exceeds an amount which represents a fair and reasonable consideration forthe rights for which the royalty is paid.

(2) In this paragraph the term `royalty` means any royalty or other amount paid asconsideration for the use of, or for the privilege of using, any copyright, patent,design, secret process or formula, trade-mark, or other like property, but does notinclude a royalty or other amount paid in respect of the operation of a mine or quarry orof other extraction of natural resources.