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HMRC internal manual

Double Taxation Relief Manual

DT: Zambia: double taxation agreement, Article 22: Income not expressly mentioned


Items of income of a resident of a Contracting State being income of a class or from sources not expressly mentioned in the foregoing Articles of this Convention in respect of which he is subject to tax in that State shall be taxable only in that State. Provided that this Article shall not be construed as affecting the taxation of income attributable to a permanent establishment which a resident of one Contracting State has in the other Contracting State.