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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Zambia: Subject to tax

The Zambian tax on dividends, interest and royalties is only reduced to the rates specified in the agreement if the United Kingdom resident recipient is subject to United Kingdom tax on the income in question.

Income not dealt with in other Articles of the agreement is only exempt from Zambian tax if the United Kingdom resident recipient is subject to United Kingdom tax on that income (Article 22).