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HMRC internal manual

Double Taxation Relief Manual

Zimbabwe: Source of income

For the purposes of the Elimination of double taxatation Article, profits, income and capital gains owned by a resident of the United Kingdom which may be taxed in Zimbabwe under the provisions of the agreement are deemed to arise from sources in Zimbabwe (Article 23(3)). Interest, royalties and technical fees are deemed to arise in the country of which the payer is a resident (Articles 11(7), 12(5) and 13(5)).