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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Kosovo: Treaty Summary

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Kosovo are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details.


Portfolio dividends 0% Article 10
Dividends on direct investments 0% Article 10
Conditions for lower rate on dividends on direct investments n/a  
Property income dividends 15% Article 10
Interest 0% Article 11
Royalties 0% Article 12
Government pensions Taxable only in Kosovo unless the individual is a resident of, and a national of, the UK. Article 18
Other pensions Taxable only in the UK (note 1) Article 17
Arbitration Yes Article 23


Note 1: lump sum payments derived from a pension scheme established in Kosovo are taxable only in Kosovo