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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Falkland Islands: Interest and royalties

Interest and royalties arising in the Falkland Islands, and paid to a United Kingdom resident who is the beneficial owner of the income, are exempt from Falkland Islands tax, except where the interest or royalty is effectively connected (see INTM153110 fifth sub-paragraph) with a business carried on by the United Kingdom resident recipient through a permanent establishment or fixed base which the recipient has in the Falkland Islands. In the latter circumstances, the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14), as the case may be, apply.