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HMRC internal manual

Double Taxation Relief Manual

Malaysia: Technical fees

Under the agreement, technical fees payable to a resident of the other country may be taxed in the source country at a rate not exceeding 8 per cent of the gross amount. Technical fees are defined as `payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature’ (Article 13(2)).

See INTM168062 for the method of calculating the amount of tax credit relief available to a United Kingdom resident.