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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation relief Manual: Guidance by country: Azerbaijan: Interest

Interest arising in Azerbaijan and paid to a resident of the UK who is the beneficial owner of the interest and is subject to tax on the interest in the UK is taxable in Azerbaijan at a rate not exceeding 10 per cent (Article 11(2)), except where the interest is effectively connected with a permanent establishment or fixed base which the UK resident recipient has in Azerbaijan. In the latter circumstances, the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14) will apply.

Notwithstanding the provisions of Article 11(2), interest arising in Azerbaijan shall be exempt from Azerbaijan tax if it is derived and beneficially owned by the UK Government or any agency or instrumentality thereof.