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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Zambia: Dividends

The Zambian tax deducted from dividends at the agreement rate of 15 per cent (5 per cent if the recipient is a United Kingdom resident company controlling, directly or indirectly, at least 25 per cent of the voting power in the Zambian company paying the dividend) qualifies for credit as a direct tax (see INTM164010(c)).

The reductions to the above rates are not given where the dividends are effectively connected with (see INTM153110 fifth sub-paragraph) a business carried on by the recipient through a permanent establishment in Zambia.

Where the dividend is paid to a United Kingdom resident company which controls, directly or indirectly, at least 10 per cent of the voting power in the Zambian company, credit is also due for the underlying tax (see INTM164010(d)).