With regard to the 2016 ratification law on international conventions (the law), the DBA falls under the category of “bilateral treaties” and does not require ratification by Parliament, unlike “international agreements”. It is therefore not necessary to ask Parliament to terminate the treaty. The termination procedure defined by the DBA itself applies. Zambia has dual taxation agreements (DTT) in place with the following countries: Zambia has not entered into totalization agreements. KPMG`s logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that acts as a coordination unit for a network of independent member companies. KPMG International does not offer audits or other customer services. These services are provided exclusively by member companies located in their respective geographic areas. KPMG International and its member companies are legally separate and distinct entities. They are not and nothing of what it contains should be interpreted in such a way that these companies fall within the relationship between parent companies, subsidiaries, agents, partners or joint ventures. No member company has any authority (real, apparent, implied or otherwise) to hire or hire KPMG International or a member company in any way. The information contained in it is general in nature and is not intended to respond to the circumstances of a particular individual or corporation. While we strive to provide accurate and timely information, there is no guarantee that this information will be correct at the time of receipt or that it will be correct in the future.
No one should react to this information after a thorough review of the particular situation without appropriate technical assistance. For more information, please contact KPMG`s Federal Tax Legislative and Regulatory Services Group at 1 202 533 4366, 1801 K Street NW, Washington, DC 20006. Since the cabinet has authorized the termination, it is now up to the Minister of Finance to notify the Government of Mauritius of a notification by June 30, 2020. The Zambian cabinet approved the end of the DBA between Zambia and Mauritius. Read a June 2020 report [PDF 462 KB], written by KPMG`s south Africa member company. The current income tax agreement will no longer enter into force in Zambia on 31 December 2020 and mauritius on 30 June 2021. The contract came into effect on June 15, 2012 and covers revenues from a range of specific sources, such as business income, dividends, interest and royalties. The current contract also provides for an exclusive tax in the country of residence of the income inflow. In the cabinet statement, the government stated that Zambia would not retain tax duties on tax dividends, interest and royalties collected in Zambia and payable to residents of Mauritius. It is not clear whether the return should be for administrative expenses for which a reduced rate of 0% applies, as the contract provides zambia for a withholding tax on dividends (5%), interest (10%) 220.127.116.11 And royalties (5%). The DBA between Zambia and Mauritius obliges the contracting parties to terminate the whistleblowing until 30 June of the calendar year, as long as the contract has been in force for at least five years. Once the notice is issued, the contract will no longer apply to Zambia on the last day of the calendar year and to Mauritius on July 1 of the following calendar year.
The Government of Zambia has stated that it intends to open negotiations for a new agreement that will introduce common tax duties and anti-abuse clauses. In a memorandum issued after the cabinet meeting of 22 June 2020, the Zambian government announced that the Double Taxation Convention (DBA) between the Government of the Republic of Zambia and the Government of the Republic of Mauritius would end on 31 December 2020. The Zambian government decided on 22 June 2020 to denounce the existing income tax agreement between Zambia and Mauritius (in force since June 2012).