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HMRC internal manual

International Manual

From
HM Revenue & Customs
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DT Agreements: Austria - Income from a UK source paid to a resident of Austria

UK royalties paid to a resident of Austria (Article 12)

Full relief from UK tax is available on UK royalties paid to a resident of Austria whois the beneficial owner of the royalties.

However, where the beneficial owner of the royalties is an Austrian company that controlsdirectly or indirectly more than 50% of the voting power of the UK company paying theroyalties, the royalties are taxable in the UK at the rate of 10%.