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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Tunisia: Source of income

For the purposes of the Elimination of double taxation Article, profits, income and capital gains owned by a resident of the United Kingdom which can be taxed in Tunisia under the provisions of the agreement are deemed to be income or gains from sources in Tunisia (Article 22(4)).

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