US-UK income tax convention, Article 12: royalties taxable only in the country of the recipient (Convention between the United States and the United Kingdom (signed 24 July 2001), Art. 12(1)-(2))
A UK holder that licenses records to a US buyer is taxed on the fee in the UK only. The treaty defines royalties widely enough to cover copyright works in audio and video and information about commercial or scientific experience.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other State. ... a) any consideration for the use of, or the right to use, any copyright of literary, artistic, scientific or other work (including computer software and cinematographic films) including works reproduced on audio or video tapes or disks or any other means of image or sound reproduction, any patent, trade mark, design or model, plan, secret formula or process, or other like right or property, or for information concerning industrial, commercial or scientific experience;”
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide