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HMRC internal manual

International Manual

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

UK interest paid to a resident of New Zealand (Article 12)

UK interest paid to a resident of New Zealand who is the beneficial owner of theinterest is taxable in the UK at 10%.

Exceptionally, UK interest may be exempted from UK income tax under the provisions ofArticle 12 paragraphs (3) and (4) of the Convention. The payments covered by theseprovisions are

  • interest paid to the Government of New Zealand, or
  • interest paid on a loan made, guaranteed or insured or any other debt-claim or credit guaranteed or insured, by the New Zealand Export Guarantee Office.

It should be clear from the information given by the claimant on the claim form whetherfull relief is appropriate. However if you have any doubts, send the file to TechnicalAdvice Group before taking further action.