Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
, see all updates

Double Taxation Relief Manual: Guidance by country: Germany, Federal Republic of: Source of income

For the purposes of giving credit for German tax, profits, income and capital gains owned by a resident of the United Kingdom which may be taxed in Germany in accordance with the Convention are deemed to have a German source (Article 23(3)).