CT600H Cross-border Royalties

CT600H Tax Return Forms for Cross-border Royalties

You need to complete these supplementary pages if:

The company is a UK company and made cross-border royalty payments after 1 October 2002, and reasonably believed that the recipient of the royalties would be entitled to treaty relief on any tax deducted. The company is entitled to make such payments without deduction of tax or at the rate specified by reference to the Double Taxation Treaty appropriate to the country of residence of the payee. More information about countries or territories that have Double Taxation Agreements with the UK can be found at Tax Treaties or :

The company is a UK company or UK permanent establishment of an EU company, and made royalty payments to an associated company in another Member State of the EU on or after 1 January 2004 (1 May 2004 for states joining the EU on that date) and reasonably believed that the beneficial owner of the royalties is exempt from UK Income Tax on those payments following the implementation of the Interest and Royalties Directive. Such payments should be made without deduction of tax.

In this context 'permanent establishment' is a fixed place of business situated in a Member State through which the business of a company of another Member State is wholly or partly carried on.

Important point

There are additional penalty provisions for failure to observe the law regarding royalty payments. Details are contained in S349E(1)(7) ICTA 1988, S98(4D) Taxes Management Act (TMA) 1970 and S98(4DA) TMA 1970 and there is provision for a Direction to be issued under S349E(1)(3) ICTA 1988 or S96(3) FA 2004, as appropriate.

HMRC have provided following Company tax return guide to form CT600 (2022) Version 3 for accounting periods starting on or after 1 April 2015 to assist Companies complete the Corporation tax returns. Further information can also be found on GOV.UK website.