SolvedDT4702 | Double Taxation Relief Manual: Cayman Islands: 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 Cayman Islands 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 | N/A | N/A |
| Dividends on direct investments | N/A | N/A |
| Conditions for lower rate on dividends on direct investments | N/A | N/A |
| Property income dividends | N/A | N/A |
| Interest | N/A | N/A |
| Royalties | N/A | N/A |
| Government pensions | Taxable only in the UK (Note 1) | 8 |
| Other pensions | Taxable only in the UK (Note 2) | 7 |
| Arbitration | No | N/A |
Note 1: If the recipient has not been continuously a resident of the UK for a period of 6 years immediately before the commencement of the payment of the pension, or 6 years immediately before the commencement of the employment to which the pension relates, then the pension is taxable only in the Cayman Islands.
Note 2: If the recipient has not been continuously a resident of the UK for a period of 6 years immediately before the commencement of the payment of the pension, or 6 years immediately before the commencement of the employment to which the pension relates, then the pension may also be taxed in the Cayman Islands.