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HMRC internal manual

Double Taxation Relief Manual

Philippines: Source of income

For the purposes of the Elimination of double taxation Article, profits, income and capital gains owned by a United Kingdom resident which may be taxed in the Philippines under the provisions of the agreement are deemed to be income or capital gains from sources in the Philippines (Article 21(3)).

Interest and royalties are deemed to arise in the country in which the payer is a resident (Articles 10(7) and 11(5)).