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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Guyana: Source of income

For the purposes of the Elimination of double taxation Article, profits and capital gains earned by a resident of the United Kingdom which may be taxed in Guyana in accordance with the agreement are deemed to arise from sources in Guyana (Article 24(4)).

Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 12(5) and 13(5)).