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HMRC internal manual

International Manual

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

UK interest paid to a resident of Portugal

Article 11 of the Convention

UK interest paid to a resident of Portugal who is the beneficial owner of the interest is taxable in the UK at 10%, provided that the interest is subject to tax in Portugal.

If the owner of the interest is not subject to tax in Portugal in respect of an interest payment no relief is available. See INTM162090 for an explanation of ‘subject to tax’.