UK International Royalty Companies

You are here: Home > International Home > UK Royalty Companies

Search :


	Untitled Document UK International Royalty Companies UK companies are widely used to receive international royalty flows arising from non-UK situated assets – typically trade marks and other types of intellectual property. Not only does the UK have the widest double tax treaty in the world (thus enabling foreign source royalty income to suffer lower or even zero rates of foreign withholding taxation) but as a result of the UK’s source rules relating to the taxation of income, onward payments of such royalty income under the terms of a licence agreement with an offshore licensor can escape UK withholding taxation altogether, and such onward payments can be deducted from the UK company’s corporation tax liabilities on its own royalty receipts. The attractions of the UK as an international royalty routing centre have been further enhanced by two recent developments: the EC Interest and Royalties Directive (effective from 1/1/2004); the abolition of the UK’s transfer pricing regime for small and medium-sized companies in their related party dealings with “qualifying” territories (effective from 1/4/2004). The effect of the abolition of the UK transfer pricing regime for small and medium-sized entities means that in appropriate cases the UK company may not have to apply the arms length principle when agreeing licence fees payable to an offshore licensor, provided that the offshore licensor is resident in a “qualifying” territory (eg Cyprus) and provided that certain other conditions are met. For further information on these services, please contact any of our specialists whose telephone, email and fax details are on this page. Alternatively, to provide us with preliminary instructions for a proposed UK company, please click here.

			Contacts
	For further information (including charges), please contact any of the following: Click contact name to email Jason Reader +44 (0)117 918 1387 Rachel Flower +44 (0) 117 918 1326 Martin Palmer +44 (0)117 918 1321 Jordans Limited 21 St Thomas Street, Bristol BS1 6JS Tel: 0117 923 0600 Fax: 0117 923 0063 DX 78161 Bristol Email Location Map

			Navigation
	UK benefits UK services International home

Jordans (Scotland) Limited t/a Oswalds, 24 Great King Street, Edinburgh EH3 6QN Tel: 0131 557 6966 Fax: 0131 556 2917 email:oswaldsinfo@oswalds.co.uk| Privacy Policy | T&Cs:terms and conditions | Statutory Information