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’.