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HMRC internal manual

International Manual

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

The DTA allows full relief from UK tax on interest beneficially owned by

* Individuals
* Pension schemes
* The state of Qatar, one of its political subdivisions or local authorities or statutory bodies
* Companies, provided that they meet one of the conditions set out in Article 11(3)(a)
* Financial institutions described at Article 11(3)(a)(vi)

or where the interest is paid by one of the payers set out in Article 11(3)(b)

Relief may be restricted, where there is a “special relationship” between the lender and borrower, on the amount of interest which exceeds that appropriate to arms-length terms. There is also a general anti-abuse provision at Article 11(7).