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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Mauritius: Source of income

For the purposes of the credit Article (Elimination of double taxation, Article 24),profits, income and capital gains owned by a resident of the United Kingdom which may betaxed in Mauritius under the provisions of the agreement are deemed to arise from sourcesin Mauritius. Interest and royalties are deemed to arise in the country of which the payeris a resident (Articles 11(6) and 12(5)).