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HMRC internal manual

Double Taxation Relief Manual

Jamaica: Management fees

Management fees arising in Jamaica and paid to a resident of the United Kingdom may be taxed in both countries.

The tax chargeable in Jamaica is limited to 12½per cent of the gross fees, but if the recipient has in Jamaica a permanent establishment with which the management fees are effectively connected (see INTM153110 fifth sub-paragraph.), or if he elects under Article 11(5) to be treated as though he had such an establishment, the Jamaican tax chargeable on those fees will be calculated as if they were industrial or commercial profits attributable to that permanent establishment and taxable under Article 5.

Whether or not the United Kingdom recipient elects to have Jamaican tax calculated in accordance with Article 11(5), the United Kingdom measure of the doubly taxed income for tax credit relief purposes will be the net management fees after deduction of expenses attributable to those fees (INTM168062).