For the purposes of the Elimination of double taxation Article,
profits, income or capital gains owned by a resident of the United
Kingdom which may be taxed in Bolivia under the provisions of the
agreement are deemed to be profits, income or capital gains from
sources in Bolivia (Article 23(3)).
Interest is deemed to arise in the country in which the
payer is resident, except where the person paying the interest,
whether he is a resident of the United Kingdom or of Bolivia or of
neither, has, in either of the countries, a permanent establishment
or fixed base in connection with which the indebtedness on which
the interest is paid was incurred, and such interest is borne by
that permanent establishment or fixed base. In such a case the
interest shall be deemed to arise in the country in which the
permanent establishment or fixed base is situated (Article 11(5)).
Royalties are deemed to arise in the country in which the
payer is resident, except where the person paying the royalties,
whether he is a resident of the United Kingdom or of Bolivia or of
neither, has, in either of the countries, a permanent establishment
or fixed base in connection with which the obligation to pay the
royalties was incurred, and such royalties are borne by that
permanent establishment or fixed base. In such a case the royalties
shall be deemed to arise in the country in which the permanent
establishment or fixed base is situated (Article 12(6)).
