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HMRC internal manual

Double Taxation Relief Manual

New Zealand: 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 may be taxed in New Zealand under the provisions of the agreement are deemed to arise from sources in New Zealand (Article 22(3)).

Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 12(7) and 13 (5)).