[INTM630460] Royalty Withholding: UK Source: Examples
Sales support – dependent agent permanent establishment
A non-UK resident group sells internet advertising space to UK customers. There is a UK dependent agent permanent establishment as contracts are concluded in the UK with the sales staff of the PE.
In order to carry out its business of selling advertising space the non-UK resident has acquired a licence from a connected party to exploit intellectual property in a defined geographical area, including the UK. A royalty is payable under the licence agreement.