SolvedDT10552 | Double Taxation Relief Manual: Jamaica: 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 Jamaica 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% | 8 |
| Dividends on direct investments | 22.5% | 8 |
| Conditions for higher rate on dividends on direct investments | A company which controls directly or indirectly at least 10% of the voting power in the company paying the dividends. | 8 |
| Property income dividends | See rates above | 8 |
| Interest | 12.5% (Note 1) | 9 |
| Royalties | 10% | 10 |
| Management fees | 12.5% (Note 2) | 11 |
| Government pensions | Taxable only in Jamaica unless the individual is ordinarily resident in the UK | 13 |
| Other pensions | Exempt from tax in Jamaica unless the pension is not subject to tax in the UK | 14 |
| Arbitration | No | N/A |
Note 1: Interest is exempt in Jamaica where it is paid in respect of a loan made, guaranteed or insured by the UK Export Credits Guarantee Department.
Note 2: A UK resident in receipt of management fees from Jamaica may instead elect for the fees to be taxed in the Jamaica on a net basis after deduction of attributable expenses, as if they had a permanent establishment in Jamaica (Article 11(5)).