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HMRC internal manual

Double Taxation Relief Manual

DT: Zambia: double taxation agreement, Article 29: Entry into force

 

(1) This Convention shall come into force on the date when the last of all such things shall have been done in the United Kingdom and Zambia as are necessary to give the Convention the force of law in the United Kingdom and Zambia respectively, and shall thereupon have effect-

(a) in the United Kingdom–

(i) as respects income tax, surtax and capital gains tax, for any year of assessment beginning on or after 6th April, 1972;

(ii) as respects corporation tax, for any financial year beginning on or after 1st April,1972;

(b) in Zambia–

as respects income for any charge year beginning on or after 1st April, 1972.

(2) The Governments of the Contracting States shall, as soon as possible, inform one another in writing of the date when the last of all such things shall have been done as are necessary to give the Convention the force of law in the United Kingdom and Zambia respectively. The date specified by the last Government to fulfil this requirement, being the date on which the Convention shall come into force in accordance with paragraph (1), shall be confirmed in writing by the Government so notified.

(3) Subject to the provisions of paragraph (4) of this Article the existing Agreement shall cease to have effect as respects taxes to which this Convention in accordance with the provisions of paragraph (1) of this Article applies.

(4) Where any provision of the existing Agreement would have afforded any greater relief from tax any such provision as aforesaid shall continue to have effect for any year of assessment or financial year or charge year beginning before the entry into force of this Convention.

(5) The existing Agreement shall terminate on the last date on which it has effect in accordance with the foregoing provisions of this Article.

(6) The termination of the existing Agreement as provided in paragraph (5) of this Article shall not revive the Arrangement made in 1947 between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Northern Rhodesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income. Upon the entry into force of this Convention that Arrangement shall terminate.

(7) In this Article the term `the existing Agreement` means the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Zambia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, that is to say the continuation, with effect from the dissolution of the Federation of Rhodesia and Nyasaland on 1st January, 1964, in force subject to certain modifications between the Government of the United Kingdom and the Government of Northern Rhodesia and from the 24th October, 1964, when Northern Rhodesia became an independent Republic under the name of Zambia, between the Government of the United Kingdom and the Government of Zambia, of the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the former Federation of Rhodesia and Nyasaland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at London on 25th November, 1955(a), as amended by the Supplementary Agreement between the Government of the United Kingdom and the Government of Zambia which was signed at Lusakaon 6th April, 1968(b).