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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Claims by financial concerns under Business Profits Article: Background to claims by foreign financial concerns

Under a longstanding practice, a claim by an overseas financial concern for interest which bears the character of income arising from their trading activities or forms part of their trading income may be relieved under the Business Profits Article (provided the Business Profits Article doesn’t clearly exclude interest, for example Kenya) in either of the following circumstances

  • there is no interest article, or
  • the conditions of the interest article are not satisfied.