DT3660.23 - DT: Bolivia: double taxation agreement, SI 95 No.2707, Article 23: Elimination of double taxation
- Subject to the provisions of the law of the United Kingdom
regarding the allowance as a credit against United Kingdom tax of
tax payable in a territory outside the United Kingdom (which shall
not affect the general principle hereof):
- Bolivian tax payable under the laws of Bolivia and in
accordance with this Convention, whether directly or by deduction,
on profits, income or chargeable gains from sources within Bolivia
(excluding in the case of a dividend, tax payable in respect of the
profits out of which the dividend is paid) shall be allowed as a
credit against any United Kingdom tax computed by reference to the
same profits, income or chargeable gains by reference to which the
Bolivian tax is computed;
- in the case of a dividend paid by a company which is a resident
of Bolivia to a company which is a resident of the United Kingdom
and which controls directly or indirectly at least 10 per cent of
the voting power in the company paying the dividend, the credit
shall take into account (in addition to any Bolivian tax for which
credit may be allowed under the provisions of sub-paragraph (a) of
this paragraph) the Bolivian tax payable by the company in respect
of the profits out of which such dividend is paid.
- In the case of a resident of the Republic of Bolivia, there
shall be excluded from the basis on which the Bolivian tax is
charged any type of income arising in the United Kingdom and any
capital situated in the United Kingdom which may be taxed in the
United Kingdom in accordance with this Convention. Nevertheless,
the Republic of Bolivia retains the right to include the items of
income and capital so excluded in determining the applicable tax.
- For the purposes of paragraphs (1) and (2) of this Article,
profits, income and capital gains owned by a resident of a
Contracting State which may be taxed in the other Contracting State
in accordance with this Convention shall be deemed to arise from
sources in that other Contracting State.
