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Posted Fri, 24 Feb 2023 10:52:24 GMT by okulah
Hi, Our company is developing mobile applications via in-house developers as well as purchasing from third party developers. We publish these apps through iOS and google play store to generate revenue. I have 2 questions regarding withholding tax on mobile application purchase. 1- Is there any withholding tax liability on purchase of mobile applications developed by third party companies abroad? We acquire all rights including but not limited to publishing, further development of apps etc. 2- Would there be any difference if the fee for the apps purchased set up on bases of future revenue generated through the app in question (like 5% of the yearly revenue in the next 5 years) Best regards
Posted Mon, 27 Feb 2023 14:43:23 GMT by HMRC Admin 32

You may wish to review guidance here.

Claiming Double Taxation Relief for companies and other concerns

Thank you.
Posted Mon, 27 Feb 2023 15:05:41 GMT by okulah
Hi, Thank you for the response. The link you have provided is related to claim and or exemption procedures for the receiver. However my question is if these kind of payments fall under the category of royalty payments that would trigger withholding tax liability for the payer. Kind regards
Posted Tue, 07 Mar 2023 13:00:43 GMT by HMRC Admin 10
As the question is vague we can only provide general advice.
Usually the recipient of the tax is the one that suffers the with holding tax.
Therefore the payer would not usually claim anything under Double Taxation , whether the tax is claimed or not  the tax should be the same.
If you do want to look how royalties are treated in the country the witholding tax is suffered, review how the appropriate treaty in the following link: Tax treaties

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