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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Israel: Subject to tax

Israeli tax on interest and royalties is only reduced to the agreement rate of 15 per cent if the recipient is subject to United Kingdom tax (see INTM162020) on the income. Similarly, pensions, other than government pensions, are only exempt from Israeli tax if the recipient is subject to tax in the United Kingdom on the income (Articles 7(1), 8(1) and 11(1)). See DT10055 as regards dividends.