58. Mr. E. P. Smith
asked the Chancellor of the Exchequer whether the proceeds due to the U.S. film industry in respect of films exhibited in Great Britain is subject to British income tax.
§ Mr. Glenvil Hall
Under Article VIII of the Double Taxation Convention between the United Kingdom and the United States, film rentals, in common with literary and patent royalties, are exempt from tax in the country of origin unless the recipient has a trading establishment there. Where a United States film producing company markets its films in this country through a subsidiary company, the subsidiary is liable to tax on the profits of distribution, and the rentals payable to the United States Company are exempt from tax. British film companies enjoy a similar exemption from United States taxation.