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HMRC internal manual

Double Taxation Relief Manual

Romania: 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 Romania under the provisions of the agreement are deemed to arise from sources in Romania (Article 24(3)).

Interest, royalties and commission are deemed to arise in the country of which the payer is a resident (Articles 11(5), 12(6) and 13(5)).