No liability to income tax arises for a non-UK resident in respect of income from a security issued by the Inter-American Development Bank if the liability only arises because one or more of circumstances A to C apply.

Circumstance A is that the security is issued in the United Kingdom or in sterling.

Circumstance B is that the income is made payable or paid in the United Kingdom or in sterling.

Circumstance C is that the Bank maintains an office or other place of business in the United Kingdom.