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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Bolivia: Source of Income

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

Interest is deemed to arise in the country in which the payer is resident, except where the person paying the interest, whether he is a resident of the United Kingdom or of Bolivia 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 shall be deemed to arise in the country in which the permanent establishment or fixed base is situated (Article 11(5)).

Royalties are deemed to arise in the country in which the payer is resident, except where the person paying the royalties, whether he is a resident of the United Kingdom or of Bolivia or of neither, has, in either of the countries, a permanent establishment or fixed base in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by that permanent establishment or fixed base. In such a case the royalties shall be deemed to arise in the country in which the permanent establishment or fixed base is situated (Article 12(6)).