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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Sudan: Source of income

For the purposes of the Elimination of double taxation Article, income, profits and capital gains owned by a United Kingdom resident which can be taxed in Sudan under the provisions of the agreement are deemed to be income or gains from sources in Sudan (Article 23(4)).

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