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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Argentina: Source of income

For the purposes of the credit Article (Elimination of double taxation), profits, income and capital gains owned by a resident of the United Kingdom which may be taxed in Argentina under the provisions of the agreement are deemed to be profits, income or capital gains from sources in Argentina (Article 23(3)).

Interest is usually deemed to arise in the State in which the payer is resident, including where the payer is the State itself or a political subdivision or local authority thereof. The exception is where the person paying the interest, whether he is a resident of the United Kingdom or of Argentina or of neither, has, in either of the countries, a permanent establishment or fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by that permanent establishment or fixed base. In such a case the interest is deemed to arise in the State in which the permanent establishment or fixed base is situated (Article 11(6)).

There is a similar source rule in relation to royalties (Article 12(5)).