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Deduction of income tax at source: Royalties

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1 ________________________________________ ________ Deduction of income tax at source: Royalties ________________________________________ ___ Updated Technical Note 27 June 2016 2 Contents Page Introduction Chapter 1 Overview 4 Chapter 2 Tax avoidance arrangements: new section 917A of the income Tax Act 2007 8 Chapter 3 Royalties : amendment to sections 906 and 907 of the income Tax Act 2007 11 Chapter 4 Royalties : changes to source rules in respect of amounts connected with UK permanent establishments 14 Chapter 5 New section 917A of the income Tax Act 2007 21 Chapter 6 Explanatory note 23 Chapter 7 Legislation amending sections 906 and 907 of the income Tax Act 2007 25 Chapter 8 Explanatory note 27 Chapter 9 Legislation introducing new Section 577A of the income Tax (Trading and Other income ) Act 2005

3 Introduction This updated Technical Note supersedes that issued on 16 March 2016. It explains legislative changes the Government has introduced in Finance Bill 2016 to ensure that all

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