Section 47 Applying section 44(2): royalty income

(1)

Subsection (2) applies if—

(a)

the arrangements are double taxation arrangements, and

(b)

royalties, as defined in the arrangements, are paid in respect of an asset in more than one foreign jurisdiction.

(2)

For the purposes of section 44(2)—

(a)

royalty income arising in more than one foreign jurisdiction in an accounting period in respect of the asset is to be treated as income arising from a single asset, and

(b)

credits available for foreign tax in respect of the royalty income are to be aggregated accordingly.

(3)

In this section “foreign jurisdiction” means a jurisdiction outside the United Kingdom.

Notes on Part 2

Modifications

C1: Pt. 2 modified by 1988 c. 1, Sch. 19ABA paras. 26-28 (as inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 34(3) (with Sch. 9 paras. 1-9, 22))
C2: Pt. 2 applied by 2010 c. 4, s. 269DL(6) (as inserted (with effect in accordance with Sch. 3 Pt. 3 of the amending Act) by Finance (No. 2) Act 2015 (c. 33), Sch. 3 para. 1)

Notes on Chapter 2

Modifications

C1: Pt. 2 applied by 2010 c. 4, s. 269DL(6) (as inserted (with effect in accordance with Sch. 3 Pt. 3 of the amending Act) by Finance (No. 2) Act 2015 (c. 33), Sch. 3 para. 1)