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5.5. Source Rules with Respect to Income Derived by Non-Residents

Income earned by non-residents from sources in Botswana is subject to tax in the country. The following income is considered as deemed to have accrued in Botswana:

Dividend Income

Dividends are treated as sourced in Botswana if they are paid out of profits derived from sources in Botswana.

Interest Income

Interest is deemed to be sourced in Botswana when paid by a Botswana resident or paid and borne by a permanent establishment in Botswana in connection with the interest obligation arisen in Botswana.

Royalty Income

The source of any commercial royalty is deemed to be situated in Botswana if it is paid by a resident of Botswana or paid and borne by a permanent establishment in Botswana.

Service Fees

The source of any management or consultancy fee is deemed to be situated in Botswana if it is paid by a resident of Botswana or paid and borne by a permanent establishment in Botswana.

Mining Income

Income derived or deemed to be derived in Botswana includes income derived from the disposal of mineral rights of land situated in Botswana and from the disposal of shares or interest in a company holding such mineral rights.