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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Papua New Guinea: Source of income

For the purposes of the Elimination of double taxation Article, profits and income owned by a United Kingdom resident which may be taxed in Papua New Guinea under the provisions of the agreement are deemed to be profits and income from sources in Papua New Guinea (Article 23(4)).

Interest is deemed to arise in the country in which the payer is resident except where the person paying the interesthas in either of the countries a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by that permanent establishment or fixed base. In such a case the interest is deemed to arise in the country in which the permanent establishment or fixed base is situated (Article 12(7)).

Royalties are deemed to arise in the country in which the payer is a resident except where the person paying the royaltieshas in either of the countries a permanent establishment or a fixed base in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base. In such a case the royalties are deemed to arise in the country in which the permanent establishment or fixed base is situated (Article 13(5)).

Technical fees are deemed to arise in the country in which the payer is a resident except where the person paying the technical feeshas in either of the countries a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by that permanent establishment or fixed base. In such a case the technical fees are deemed to arise in the country in which the permanent establishment or fixed base is situated (Article 14(6)).