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HMRC internal manual

Double Taxation Relief Manual

Malaysia: Source of income

For the purposes of the Elimination of double taxation Article, profits, income, and capital gains derived by a United Kingdom resident which can be taxed in Malaysia under the provisions of the agreement are deemed to have a source in Malaysia (Article 24(3)). Interest and royalties are deemed to arise in the country in which the payer is resident (Articles 11(5) and 12(5)).