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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Zambia: double taxation agreement, Article 20: Governmental functions

 

(1) Remuneration (other than pensions) paid by the Government of a Contracting State to any individual for services rendered to that Government in the discharge of governmental functions shall be exempt from tax in the other Contracting State if the individual is not ordinarily resident in that other Contracting State or is ordinarily resident in that other Contracting State solely for the purpose of rendering those services.

(2) Any pension paid by the Government of a Contracting State to any individual for services rendered to that Government in the discharge of governmental functions shall be exempt from tax in the other Contracting State if immediately prior to the cessation of the services to which the pension relates the remuneration therefore was exempt from tax in that other Contracting State (whether under paragraph (1) of this Article orotherwise).

(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by the Government of either Contracting State for purposes of profit.

(4) Any pension paid to an individual for services rendered in the discharge ofgovernmental functions which would have been exempt from tax in a Contracting State if the existing Agreement had continued in force shall be exempt from tax in that Contracting State under this Convention. In this paragraph the term `the existing Agreement` has the same meaning as in paragraph (7) of Article 29 of this Convention.