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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Ghana: Source of income

For the purposes of the Elimination of double taxation Article, profits or income owned by a United Kingdom resident which may be taxed in Ghana under the provisions of the agreement are deemed to arise from sources in Ghana. Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 11(5) and 12(5)).