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HMRC internal manual

Double Taxation Relief Manual

India: Source of income

For the purposes of the Elimination of double taxation Article, profits, income and chargeable gains owned by a resident of the United Kingdom which may be taxed in India under the provisions of the agreement are deemed to arise from a source in India (Article 24(7)).

Interest, royalties and fees for technical services are deemed to arise in the country of which the payer is a resident (Articles 12(7) and 13(7).