DT20853 - Zambia: Treaty Summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Zambia is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject	Comments	Article
Portfolio dividends	5%	Article 10
Dividends on direct investments	5%	Article 10
Conditions for lower rate on dividends on direct investments	n/a
Property income dividends	15%	Article 10
Interest	10% (note 1)	Article 11
Royalties	5%	Article 12
Government pensions	Taxable only in Zambia unless the individual is a resident of, and a national of, the UK	Article 18
Other pensions and annuities	Taxable in the UK (note 2)	Article 17
Arbitration	No	Article 25

Note 1: Interest paid in the following circumstances is taxable only in the UK if:

• The beneficial owner is the UK government, the Bank of England, a political subdivision or local authority thereof.
• The beneficial owner is any agency wholly owned by the UK government, political subdivision or local authority thereof.

Note 2: Provided the pension is subject to tax in the UK. Lump sum payments are taxable only in the UK. Social security pensions are taxable only in Zambia.