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HMRC internal manual

International Manual

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

UK interest paid to a resident of Jamaica (Article 9)

UK interest paid to its beneficial owner who is a resident of Jamaica may be taxed inthe UK at 12½%.

But no relief is due where the beneficial owner of the interest:

  • is not subject to tax on the interest in Jamaica, and
  • sells (or makes a contract to sell) the debt from which the interest arose within three months of the date when they acquired it