Income Tax Act 2007 section 909

Royalty payments: further provision

Section 909 provides supplementary rules for the deduction of income tax at source from royalty and periodic payments made to owners whose usual place of abode is abroad, as covered by section 906.

• A royalty or periodic payment is treated as made for tax purposes at the point it is first made, not when it passes through any intermediary or agent
• Any agreement to make a payment without deducting the required income tax is void and unenforceable
• The withholding tax rules apply equally to payments on account of royalties, not just to final royalty payments themselves
• The same withholding tax rules also extend to payments on account of sums payable periodically