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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Overseas Collecting Societies: Undertaking required by the UK Collecting Society


“Subject to the granting of the exemption authority, we give our undertaking that after each distribution to (Overseas Collecting Society) and before our next distribution to them, we will obtain from (Overseas Collecting Society) a list of their members who do not satisfy the conditions for DT relief. That is, where the member is not

  • resident in (country of Overseas Collecting Society) for the purposes of (country) tax


  • themselves the beneficial owner of the rights to the royalties

We also give our assurance that the UK income tax due on the distributions made to any members of (Overseas Collecting Society) who are not entitled to benefit from the terms of the UK/(country of Overseas Collecting Society) Double Taxation Agreement (DTA) will be deducted from the next distribution made to (Overseas Collecting Society) and accounted for to our own Inspector of Taxes.”