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HMRC internal manual

Double Taxation Relief Manual

Kenya: Source of income

For the purposes of the Elimination of double taxation Article , income, profits and capital gains owned by a resident of one country which may be taxed in the other country under the agreement are deemed to arise from a source in the other country (Article 26(4)). Interest, royalties and management fees are deemed to arise in the country of which the payer is a resident (Articles 12(6), 13(5) and 14(6)).