73. Source of payments

payments received in respect of employment –

to the extent derived in respect of employment in Sri Lanka, wherever paid; or

if paid by, or on behalf of, the Government of

dividends paid by a resident company;

interest, charges, annuities, a royalty, technical service fee, or similar payment if –

paid by a resident person, other than as an expenditure of a business carried on by the resident person through a permanent establishment outside Sri Lanka; or

paid by a non-resident person as an expenditure of a business carried on by the non-resident person through a Sri Lankan permanent establishment;

winnings from lottery, betting, or gambling relating to a game of chance held in Sri Lanka;

natural resource payments made in respect of or calculated by reference to natural resources taken from land or the sea situated within Sri Lanka or its territorial waters;

rent paid for the use of, right to use or forbearance from using an asset situated in Sri Lanka;

premiums for general insurance paid to and proceeds from general insurance paid by a person in respect of the insurance of any risk in Sri Lanka;

payments received by a person who conducts a relevant transport business in respect of –

the carriage of passengers who embark or cargo, mail or other moveable tangible assets that are embarked in Sri Lanka, other than as a result of transhipment; or

rental of containers and related equipment which are supplementary or incidental to carriage referred to in subparagraph (i);

payments received by a person who conducts a business of transmitting messages by cable, radio, optical fibre or satellite or electronic communication in respect of the transmission of messages by apparatus established in Sri Lanka, whether or not such messages originate in Sri Lanka;

payments, including service fees, of a type not mentioned in paragraph (c), (h) or (i) for or attributable to service rendered or a forbearance from rendering service –

in Sri Lanka, regardless of the place of payment; or

where the payer is the Government of Sri

proceeds of life insurance and retirement, termination and pension payments not falling within paragraph (a) if –

paid by a resident person, other than as an expenditure of a business carried on by the resident person through a permanent establishment outside Sri Lanka;

paid by a non-resident person as an expenditure of a business carried on by the non-resident person through a Sri Lankan permanent establishment; or

paid by, or on behalf of, the Government of

gifts and other ex gratia payments to the extent received in respect of business or investment conducted with domestic assets; and

payments not mentioned in the above paragraphs –

made in respect of the acquisition of a domestic asset, incurring of a domestic liability or realisation of such an asset or liability;

received in respect of activity conducted or a forbearance from conducting activity in

made to any foreign entertainer or artist for activity relating to Sri Lanka.