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HMRC internal manual

Double Taxation Relief Manual

Ivory Coast: Management fees

Management fees arising in the Ivory Coast and paid to a resident of the United Kingdom may be taxed in both countries. The tax charged in the Ivory Coast is limited to 10 per cent of the gross fees.

If, however, the recipient has in the Ivory Coast a permanent establishment or fixed base with which the management fees are effectively connected (see INTM153110 fifth sub-paragraph), of if he elects under Article 13(5) to be treated as though he had such a permanent establishment or fixed base, the Ivory Coast tax chargeable on those fees will be calculated as though they were industrial and commercial profits of the permanent establishment or income or the fixed base and taxable under Articles 7 or 15 respectively.

Whether or not the United Kingdom resident recipient elects to have Ivory Coast tax calculated in accordance with Article 13(5), the United Kingdom measure of the doubly taxed income for purposes of tax credit relief will be the net management fees after deduction of expenses attributable to those fees (INTM168062).