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HMRC internal manual

Double Taxation Relief Manual

Zambia: Source of income

For the purposes of the Elimination of double taxation Article, profits, income and capital gains owned by a resident of the United Kingdom which may be taxed in Zambia under the provisions of the agreement are deemed to arise from sources within Zambia (Article 23(3)).

Interest is deemed to arise in the country of which the payer is a resident (Article 12(5)).