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HMRC internal manual

International Manual

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

UK royalties paid to a resident of India (Article 13)

Scope of Article 13

Article 13 covers both royalties and fees for technical services. The notes below use ‘royalties’ to refer to both types of payment, which are defined and distinguished from one another by paragraphs (3), (4), and (5) of the article.

Please refer to Technical Advice Group where it is not clear how any payment should be categorised.

UK royalties paid from the 6 April 1999

UK royalties paid to a resident of India who is the beneficial owner of the royalties are taxable in the UK at 15%.

UK royalties paid to a resident of India who is the beneficial owner of the royalties that are paid in respect of the use of, or of the right to use, any industrial, commercial or scientific equipment are taxable in the UK at 10%. However, this does not extend to UK royalties that are paid to an enterprise of India in respect of the operation of ships or aircraft in international traffic that will be taxable in the UK at 15%.