There is a duty to deduct a sum representing income tax from a payment of a qualifying annual payment or a patent royalty. See A4.432 and A4.435 respectively for the duty to deduct, and for circumstances in which the duty does not apply. The following commentary describes a further exception from the duty to deduct which applies to both qualifying annual payments and patent royalties in certain cases where the payment or royalty is made under a liability incurred for consideration which either consists of a dividend or is
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