DT17902 | Double Taxation Relief Manual: Swaziland: source of income
From HM Revenue & Customs · Double Taxation Relief Manual
For the purposes of the Elimination of double taxation Article, income, profits and capital gains owned by a resident of the United Kingdom which can be taxed in Swaziland under the provisions of the agreement are deemed to be income or gains from sources in Swaziland (Article 21(3)).