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HMRC internal manual

International Manual

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

UK royalties paid to a resident of Portugal

Article 12 of the Convention

UK royalties paid to a resident of Portugal who is the beneficial owner of the royalties is taxable in the UK at 5%, provided that the interest is subject to tax in Portugal.

If the owner of the royalty is not subject to tax in Portugal in respect of a royalty payment no relief is available. See INTM162090 for an explanation of ‘subject to tax’.