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HMRC internal manual

Double Taxation Relief Manual

Jamaica: Source of income

For the purposes of the Elimination of double taxation Article, profits, income and chargeable gains owned by a resident of the United Kingdom which can be taxed in Jamaica under the provisions of the agreement are deemed to arise from sources in Jamaica (Article 23(4)). Interest, royalties and management fees are deemed to arise in the country of which the payer is a resident (Articles 9(7), 10(5) and 11(6)).