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HMRC internal manual

Double Taxation Relief Manual

Trinidad and Tobago: Technical fees

The agreement provides that technical fees (defined as payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature) arising in Trinidad and Tobago and paid to a United Kingdom resident may be taxed in both countries.

The tax chargeable in Trinidad and Tobago is limited to 10 per cent of the gross fees, but if the recipient has in Trinidad and Tobago a permanent establishment with which the fees are effectively connected (see INTM153110 fifth sub-paragraph) the Trinidad and Tobago tax chargeable on those fees will be calculated as if they were profits attributable to that permanent establishment and taxable under Article 7 (Article 13).

Whether the Trinidad and Tobago tax is charged on the gross fees or in accordance with Article 7, the United Kingdom measure of the income will be the net fees after deduction of expenses attributable to those fees ( INTM168020).