SolvedDT2552 | Double Taxation Relief Manual: Armenia: Treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Armenia are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state 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% | 10 |
| Dividends on direct investments | 5% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which controls directly or indirectly, at least 25% of the share capital of the payer | 10 |
| Property income dividends | 15% | 10 |
| Interest | 5% (Note 1) | 11 |
| Royalties | 5% | 12 |
| Government pensions | Taxable by the paying state, except where the individual is a national and resident of the other state | 18 |
| Other pensions | Taxable in state of residence, except lump sums taxable in the state of source | 17 |
| Arbitration | Yes | 26 |
Note 1: Interest paid in the following circumstances is taxable only in the state of residence of the beneficial owner of the interest:
Where the beneficial owner is the UK Government, a political sub-division thereof, a local authority, the Bank of England or any institution wholly owned by the Government.