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HMRC internal manual

International Manual

DT Agreements: Cyprus - Income from a UK source paid to a resident of Cyprus

UK royalties paid to a resident of Cyprus (Article 13).

Full relief from UK tax is available on most UK royalties that are paid to a resident of Cyprus who is the beneficial owner of the royalties.

The treaty provides for royalties that are paid in respect of cinematograph films including films and video tapes for television may be taxed in, and according to the law of, the Contracting State from which they are derived, but the tax so charged shall not exceed 5 per cent of the gross amount of such royalties. Because of the provisions at ITA07/S907(2) you should not need to deal with an application or claim for treaty benefits in respect of this type of income. See also INTM348060 ‘Special Tax Benefits’.