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HMRC internal manual

Double Taxation Relief Manual

DT: Jamaica: double taxation agreement, Article 19: Independent personal services

  1. Where a resident of one of the territories derives income from the other territory in respect of professional services or other independent activities of a similar character he shall be subject to tax in that other territory but only in respect of such part of that income as is attributable to his services in that other territory. In determining the income attributable to such services, there shall be allowed as a deduction expenses incurred in the performance of those services including reasonable administrative and general expenses so incurred, whether in the territory in which the services are performed or elsewhere
  2. The term `professional services` includes especially independent scientific literary, artistic, educational and teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.