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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Chile: Source of income

For the purposes of the credit Article (Elimination of double taxation), profits, income and capital gains owned by a United Kingdom resident which may be taxed in Chile under the provisions of the agreement are deemed to arise from sources in Chile (Article 21(3)). Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 11(5) and 12(5)).