DT6952 - Double Taxation Relief Manual: Guidance by country: Faroes: 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 the Faroes 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	15% (Note 1)	10
Dividends on direct investments	5%	10
Conditions for lower rate on dividends on direct investments	The beneficial owner must be a company which controls directly at least 10% of the voting power in the company paying the dividends	10
Interest	0%	11
Royalties	0%	12
Government pensions	Taxable only in the Faroes unless the individual is a resident, and national of, the UK	18
Other pensions	Taxable only in the UK (Note 2)	17
Arbitration	No	N/A

Note 1: Dividends beneficially owned by a pension scheme are taxable only in the state in which the pension scheme is resident.

Note 2: Social security pensions are taxable only in the Faroes.