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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Algeria: Treaty Summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Algeria is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Portfolio dividends 15% Article 10
     
Dividends on direct investments 5% Article 10
Conditions for lower rate on dividends on direct investments The beneficial owner must be a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividends  
Property income dividends 15% Article 10
Interest 7% (note 1) Article 11
Royalties 10% Article 12
Government pensions Taxable only in Algeria unless the individual is a resident of, and a national of, the UK Article 18
Other pensions Taxable in Algeria (note 2) Article 17
Arbitration Yes Article 23

Note 1: Interest paid in the following circumstances is taxable only in the state of residence of the beneficial owner of the interest:

  • The beneficial owner is the UK or the Bank of England, a political subdivision or local authority thereof;
  • If the interest is paid by Algeria or by a political subdivision, a local authority or statutory body thereof; or
  • If the interest is paid in respect of a loan, debt-claim or credit that is owed to, or made, provided, guaranteed or insured by, the UK or a political subdivision, local authority or export financing agency thereof.

Note 2: Social security pensions are taxable only in Algeria