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HMRC internal manual

International Manual

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HM Revenue & Customs
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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.