SolvedDT7052 | Double Taxation Relief Manual: Fiji: 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 Fiji 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% (Note 1) | 11 |
| Dividends on direct investments | 0% | 11 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which holds directly or indirectly at least 10% of the voting power of the payer | 11 |
| Property income dividends | As above | 11 |
| Interest | 10% | 12 |
| Royalties and management fees | 15% | 13 |
| Government pensions | Taxable only in Fiji if the individual is not ordinarily resident in the UK | 19 |
| Other pensions | Taxable only in the UK | 18 |
| Arbitration | No | N/A |
Note 1: Fijian tax deducted from dividends at the convention rate of 15% qualifies for credit as a direct tax (see INTM164010(c)).