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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Lesotho: Technical fees

The agreement contains a separate Technical Fees Article (Article 13) . It covers payments, other than those to an employee, for any services of a technical, managerial or consultancy nature.

The country in which the fees arise may tax the payments up to a rate not exceeding 10 per cent of the gross fees, except where the recipient carries on business in that country through a permanent establishment or fixed base, in which case the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 15) apply.

Where the recipient of the fees does not have a permanent establishment or fixed base in the country in which the fees arise, he can nevertheless elect, for any year of assessment or financial year, to have the tax on the fees calculated as if he did have a permanent establishment or fixed base in that country, i.e. under the provisions of Article 7 or Article15. Credit relief is available to a United Kingdom resident recipient for either Lesotho tax paid on the gross fees or for the tax calculated in accordance with Article 7 or Article 15.