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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Gambia: Source of income

Article 20(4) deems, for the purposes of the Elimination of double taxation Article, profits, income or chargeable gains owned by a United Kingdom resident which may be taxed in Gambia under the provisions of the agreement, to arise from a source in Gambia. Interest, royalties and technical fees are deemed to arise in the country of which the payer is a resident (Articles 12(6), 13(5) and 14(6)).