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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Botswana: Source of income

For the purposes of the credit Article (Elimination of double taxation), profits, incomeand capital gains derived by a resident of one of the countries which may be taxed in theother country in accordance with the provisions of the agreement are deemed to have theirsource in that other country (Article 23(6) and see INTM161120(c)).