Taxation (International and Other Provisions) Act 2010 section 47

Applying section 44(2): royalty income

Section 47 deals with the aggregation of royalty income and related foreign tax credits where royalties for a single asset are paid across more than one foreign country under a double taxation agreement.

• This section applies only where double taxation arrangements are in place and royalties (as defined by those arrangements) for a single asset are paid in more than one foreign jurisdiction.
• Royalty income arising from the same asset in multiple foreign jurisdictions during an accounting period must be treated as income from a single asset for the purposes of calculating double taxation relief by way of credit.
• Foreign tax credits available on that royalty income from different jurisdictions are aggregated accordingly, rather than being computed separately for each jurisdiction.
• A "foreign jurisdiction" means any jurisdiction outside the United Kingdom.