DT3853 - Double Taxation Relief Manual: Guidance by country: Botswana: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Botswana is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject Comments Article
Portfolio dividends 12% 10
Dividends on direct investments 5% 10
Conditions for lower rate on dividends on direct investments A company which holds directly or indirectly at least 25% of the voting power of the payer 10
Property income dividends 12% 10
Interest 10% (Note 1) 11
Royalties 10% 12
Technical fees 7.5% 13
Government pensions Taxable only in Botswana unless the individual is a resident and a national of the UK 20
Other pensions Taxable only in the UK (Note 2) 19
Arbitration No N/A

Note 1: Interest is taxable only in the UK where such interest is paid:

  • to the Government of the UK or a UK local authority
  • to the Commonwealth Development Corporation
  • in respect of a loan made, guaranteed or insured by the United Kingdom Export Credits Guarantee Department

Note 2: The individual must be subject to tax on that pension or annuity.