HC Deb 02 November 1948 vol 457 cc681-2
55. Mr. Mikardo

asked the Chancellor of the Exchequer what taxation is paid in France on royalties paid to patentees of British nationality; and if he is satisfied that this does not exceed the taxation on royalties paid to patentees of United States nationality.

Sir S. Cripps

Patent royalties payable to British nationals are chargeable to tax in France at a rate, I understand, of 16.8 per cent., subject in appropriate cases to a relief by way of personal allowances. The same rate of tax is imposed on French nationals. Under a double taxation convention between the United States of America and France, each country has agreed in general to exempt from tax patent royalties flowing to residents of the other country and, accordingly, patent royalties payable from France to United States nationals are exempt from French tax. The United Kingdom has for some time been awaiting the convenience of French representatives to open negotiations for an extension of the existing limited taxation treaty between the two countries, an extension under which reciprocal exemption for patent royalties would, it is hoped, be included.