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HMRC internal manual

Double Taxation Relief Manual

Guidance by country: China: source of income

For the purposes of the Elimination of double taxation Article, profits, income and capital gains owned by a United Kingdom resident which may be taxed in China under the provisions of the agreement are deemed to arise from sources in China (Article 22(2)(d)).

Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 11(6) and 12(5)).