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HMRC internal manual

Double Taxation Relief Manual

Ivory Coast: Source of income

For the purposes of the Elimination of double taxationArticle profits, income and capital gains owned by a resident of the United Kingdom which can be taxed in the Ivory Coast under the provisions of the agreement are deemed to arise in the Ivory Coast (Article 23(4)).

Interest, royalties and management fees are deemed to arise in the country of which the payer is a resident (Articles 11(6), 12(5) and 13(6)).