SolvedDT10252 | Double Taxation Relief Manual: Ivory Coast: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the Ivory Coast is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15%/18% (Note 1) | 10 |
| Dividends on direct investments | 15%/18% (Note 1) | 10 |
| Conditions for lower rate on dividends on direct investments | N/A | N/A |
| Property income dividends | See rates above | 10 |
| Interest | 15% (Note 2) | 11 |
| Royalties | 10% | 12 |
| Management fees | 10% (Note 3) | 13 |
| Government pensions | Taxable only in the Ivory Coast unless the individual is a resident of the UK and not an Ivory Coast national | 20 |
| Other pensions | Taxable only in the UK | 19 |
| Arbitration | No | N/A |
Note 1: The higher rate of 18% applies if the dividend is paid by an Ivory Coast company which is exempt from tax on its profits there or does not pay tax at the normal rates.
Note 2: Interest is exempt from tax in the Ivory Coast where it is paid to the UK government or political subdivision, or a UK local authority.
Note 3: A UK resident in receipt of management fees from the Ivory Coast may instead elect for the fees to be taxed in the Ivory Coast on a net basis after deduction of attributable expenses, as if they had a permanent establishment in the Ivory Coast (Article 13(5)).