SolvedDT7653 | Double Taxation Relief Manual: Gambia: 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 Gambia 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 | 0% (Note 1) | 11 |
| Dividends on direct investments | 0% (Note 1) | 11 |
| Conditions for lower rate on dividends on direct investments | The recipient must be subject to tax in the UK | 11 |
| Property income dividends | 0% (Note 1) | 11 |
| Interest | 15% (Note 2 and 3) | 12 |
| Royalties | 12.5% (Note 2) | 13 |
| Technical fees | 15% (Note 2) | 14 |
| Government pensions | Taxable only in Gambia unless the individual is a UK national | 17 |
| Other pensions | Taxable only in Gambia | 18 |
| Arbitration | No | N/A |
Note 1: The Gambian tax deducted from a dividend paid by a Gambian company is company tax (see INTM164010(e)). Credit for such tax is not due to portfolio shareholders (see INTM164010(f)).
Note 2: The individual must also be subject to tax in the UK on the same income to be entitled to the treaty rate.
Note 3: Interest is taxable only in the state of residence of the beneficial owner where such interest is paid:
to the UK Government or local authority or any wholly owned agency
to the Bank of England