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HMRC internal manual

Double Taxation Relief Manual

Uganda: Interest and royalties

The rate of Ugandan tax on interest and royalties arising in Uganda which are beneficially owned by a resident of the United Kingdom is limited to a maximum of 15 per cent (Articles 11(2) and 12(2)). This restriction does not apply where the interest or royalties are effectively connected (see INTM153110) with a permanent establishment or fixed base which the beneficial owner of the interest or royalties has in Uganda (Article 11(5) and 12(4)).

Interest arising in either Uganda or the United Kingdom which is beneficially owned by the Government (or a local authority or Government agency) of the other country, or which is connected with a loan guaranteed or insured by the Government (or a Government agency) of the other country, is exempt from tax in the source country (Article 11(3)).