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HMRC internal manual

Double Taxation Relief Manual

Fiji: 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 under the provisions of the agreement are deemed to have their source in that other country (Article 22(4) and see INTM161120 (c)).

Interest, royalties and management fees are deemed to arise in the country of which the payer is a resident (Articles 12(3) and 13(7)).