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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Bolivia: Interest and royalties

Interest or royalties arising in Bolivia and paid to a resident of the UK who is the beneficial owner of the interest or royalties are taxable in Bolivia at a rate not exceeding 15 per cent (Articles 11(2) and 12(2)), except where the interest or royalty is effectively connected with a permanent establishment or fixed base which the UK-resident recipient has in Bolivia. In the latter circumstances the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14) will apply.

Where interest has a Bolivian source and is paid to a UK resident who is the beneficial owner of the interest, in respect of a loan guaranteed by the United Kingdom Export Credits Guarantee Department, it is exempted from Bolivian tax. Similarly, the interest is exempt from tax in Bolivia if it is paid to the United Kingdom Government (Article 11 9 &(10)).