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Double Taxation Relief Manual

DT8752 - Double Taxation Relief Manual: Guyana: treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Guyana is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk

Subject

Comments

Article

Portfolio dividends

15%

11

Dividends on direct investments

10%

11

Conditions for lower rate on dividends on direct investments

The beneficial owner controls directly or indirectly at least 10% of the voting power in the company paying the dividends

11

Property income dividends

15%

11

Interest

15%

12

Royalties

10%

13

Government pensions

Taxable only in Guyana unless the individual is a UK national without also being a Guyana national

21

Other pensions

Taxable only in the UK

20

Arbitration

No

N/A