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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: Armenia: interest

Where the beneficial owner of interest is a resident of the United Kingdom, withholding tax at a rate not exceeding 5% is payable.

However, under the Agreement, interest is payable gross where the beneficial owner is the United Kingdom Government, a political sub-division thereof, a local authority, the Bank of England or any institution wholly owned by the Government.

The reduced rates provided by the treaty are not given if the interest is effectively connected (see INTM153110 eighth sub-paragraph) with a permanent establishment which the United Kingdom resident recipient has in Armenia.