DT Agreements: Germany - Income from a UK source paid to a resident of Germany
UK royalties paid to a resident of Germany
Full relief from UK tax is available for UK royalties that are paid to a resident of Germany provided that the royalties are ‘subject to tax’ in Germany. See Article VII.
If the owner of the royalties is not subject to tax - see INTM162090 for an explanation of ‘subject to tax’ - in Germany in respect of a royalty payment no relief is available.