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HMRC internal manual

International Manual

UK residents with foreign income or gains: income arising abroad: Royalties

Where royalties are pure income profit, and are assessed to tax on a UK resident recipient, credit is due, either under the provisions of the credit Article in an agreement or unilaterally, for any foreign tax withheld from the royalties against the tax. See INTM168060 where the royalties are not pure income profit of the UK resident recipient, because they are trading receipts (for example, a UK concern licenses foreign residents to use its patents in return for royalties).