SolvedDT2302 | Double Taxation Relief Manual: Algeria: 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 Algeria 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% | 10 |
| Dividends on direct investments | 5% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends | |
| Property income dividends | 15% | 10 |
| Interest | 7% (Note 1) | 11 |
| Royalties | 10% | 12 |
| Government pensions | Taxable only in Algeria unless the individual is a resident, and national of, the UK | 18 |
| Other pensions | Taxable in Algeria (Note 2) | 17 |
| Arbitration | Yes | 23 |
Note 1: Interest paid in the following circumstances is taxable only in the UK if:
the beneficial owner is the UK or the Bank of England, a political subdivision or local authority thereof;
if the interest is paid by Algeria or by a political subdivision, a local authority or statutory body thereof; or
if the interest is paid in respect of a loan, debt-claim or credit that is owed to, or made, provided, guaranteed or insured by, the UK or a political subdivision, local authority or export financing agency thereof.
Note 2: Social security pensions are taxable only in Algeria.