SolvedDT18552 | Double Taxation Relief Manual: Tajikistan: 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 Tajikistan 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 | 10% (Note 1) | Article 10 |
| Dividends on direct investments | 5% | Article 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner is company which holds directly at least 10 per cent of the capital of the company paying the dividends | Article 10 |
| Property income dividends | 15% | Article 10 |
| Interest | 10% | Article 11 |
| Royalties | 7% | Article 12 |
| Government pensions | Taxable only in Tajikistan unless the individual is a resident of, and a national of, the UK | Article 18 |
| Other pensions | Taxable only in the UK (Note 2) | Article 17 |
| Arbitration | No | N/A |
Note 1: Dividends beneficially owned by a pension scheme established in the UK are taxable in Tajikistan at a rate not exceeding 5%.
Note 2: Lump-sum payments derived from a pension scheme established in Tajikistan are taxable only in Tajikistan.