DT8153 - Gibraltar: Notes

Note 1: Although the Agreement allows for taxation by the territory in which the interest arises, in accordance with domestic law, there are many exemptions listed in paragraph 3 of Article 11, which make the interest taxable only in the territory of residence of the beneficial owner of the interest, for example the other territory itself, a bank or building society, a pension scheme or an individual.

Note 2: Although the Agreement allows for taxation by the territory in which the royalty arises, in accordance with domestic law, there are many exemptions listed in paragraph 3 of Article 12, which make the royalty taxable only in the territory of residence of the beneficial owner of the royalty, for example where the owner is the other territory itself or an individual.