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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Lesotho: Source of income

Article 23(3) of the agreement deems profits and income owned by a United Kingdom resident which may be taxed in Lesotho under the provisions of the agreement to arise from sources in Lesotho.

Interest is deemed to arise in the country in which the payer is resident, except where the person paying the interest has, in either of the countries, a permanent establishment or fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by that permanent establishment or fixed base. In such a case the interest is deemed to arise in the country in which the permanent establishment or fixed base is situated (Article 11(5)).

Royalties are deemed to arise in the country in which the payer is resident, except where the person paying the royalties has, in either of the countries, a permanent establishment or fixed base in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by that permanent establishment or fixed base. In such a case the royalties are deemed to arise in the country in which the permanent establishment or fixed base is situated (Article 12(5)).