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HMRC internal manual

International Manual

From:
HM Revenue & Customs
Published:
Updated:
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  1. Contents
  2. INTM347375

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

UK interest paid to a resident of Canada (Article 11)

UK interest paid to a resident of Canada who is the beneficial owner of the interest istaxable in the UK at 10%.

But full relief is available if the UK interest is paid in respect of a loan made,guaranteed or insured, or a credit extended, guaranteed or insured, by the ExportDevelopment Corporation (later Export Development Canada).

And there is no relief if the beneficial owner of the interest residentin Canada:

  • is not subject to tax in Canada on the interest, and
  • sells or makes a contract to sell the holding from which the interest is derived within three months of the date on which that owner acquired the holding.
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