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HMRC internal manual

International Manual

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

UK interest paid to a resident of Japan (Article 12)

UK interest paid to its beneficial owner who is resident in Japan is taxable in the UKat 10%.

If the beneficial owner is not subject to tax [INSERT Xref to DT 802replacement] in Japan in respect of an interest payment from a security that is quoted ona stock exchange (see INTM342070 for information aboutinterest payments made after 31 March 2001) no relief is available if the security is soldwithin 3 months of the date on which it was acquired.

The answers to question 7 in Part B of the form Japan/Company, or to thequestion in Part D of the form Japan/Individual as appropriate, will helpyou to decide if this test for relief from UK tax has to be considered.