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HMRC internal manual

Double Taxation Relief Manual

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


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.