ARTICLE 17

U.S. Income Tax Treaty — Jamaica Income Tax Treaty - 1980 · 2026-10-03 edition · updated 2026-10-04 · United States

Investment or Holding Companies

If 25 per cent or more of the capital of a company which is a resident of a Contracting State is owned directly or indirectly by individuals who are not residents of that State, and if by reason of special measures the tax imposed by that State on that company with respect to dividends, interest or royalties arising in the other Contracting State is substantially less than the tax

generally imposed by the first-mentioned State on corporate business profits, then, notwithstanding the provisions of Articles 10 (Dividends), 11 (Interest), or 12 (Royalties), that other State may tax such dividends, interest or royalties. For the purpose of this Article, the source of dividends, interest or royalties shall be determined in accordance with paragraph 3(a), (b), or (c) of Article 24 (Relief from Double Taxation).

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▸Contents — U.S. Income Tax Treaty — Jamaica Income Tax Treaty - 1980

U.S. Income Tax Treaty — Jamaica Income Tax Treaty - 1980

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