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HMRC internal manual

Double Taxation Relief Manual

Egypt: Source of income

For the purposes of the Elimination of double taxation Article, profits, income and capital gains derived by a resident of one of the countries which may be taxed in the other country in accordance with the provisions of the agreement are deemed to have their source in that other country (Article 22(4) and see INTM161120(c)). Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 11(7) and 12(5)).