SolvedDT8053 | Double Taxation Manual: Ghana: 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 Ghana 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 and 2) | 10 |
| Dividends on direct investments | 7.5% (Note 1 and 2) | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which controls, directly or indirectly, at least 10% of the voting power in the company paying the dividends | 10 |
| Property income dividends | 15% (Note 1 and 2) | 10 |
| Interest | 12.5% (Note 1 and 3) | 11 |
| Royalties | 12.5% (Note 1) | 12 |
| Management and technical fees | 10% | 17 |
| Government pensions | Taxable only in Ghana unless the individual is a resident and national of the UK | 20 |
| Other pensions | Taxable only in the UK (Note 1) | 19 |
| Arbitration | No | N/A |
Note 1: The beneficial owner must also be subject to tax in the UK.
Note 2: The Ghanaian tax deducted from dividends at the convention rate of 15% (or 7.5% where the beneficial owner of the dividend is a company which controls, directly or indirectly, at least 10% of the voting power in the company paying the dividends) qualifies for credit as a direct tax (see INTM164010(c)).
Note 3: Interest is taxable only in the UK where such interest is paid:
in respect of a loan made, guaranteed or insured, or any other debt-claim or credit guaranteed or insured by the UK Export Credits Guarantee Department
it is derived and beneficially owned by the Government of the UK or a local authority thereof or any agency or instrumentality of the UK or local authority or by the Commonwealth Development Corporation