|To a company controlling 25% or more of the voting power and holding 25% or more of the shares||5||10|
|From a DSE-listed company||5||5|
|Land and buildings||10||10|
|Natural resource payment||15||15|
|Director fees (other than full time service)||15||15|
|Money transfer commission paid to money transfer agent||10||N/A|
|Fees paid to commercial bank agents and digital payment agents||10||N/A|
|Payments for goods by government institutions||2||N/A|
|Payments to suppliers of agro-products, livestock, and fisheries*||2**||N/A|
* Exception of payments made by agricultural marketing cooperative societies and cooperative unions.
** The 2% rate is not specified in the Finance Act 2021, but this appears to be an oversight as the rate was mentioned in the 2021/2022 budget speech. The expectation is that it will be introduced through a Government Notice.
Double tax treaty (DTT) rates
|Dividend||Interest (7)||Royalties||Management / technical fees|
|Domestic rate (1)||10||10||15||15|
|South Africa||10/20 (2)||10||10||0|
|Zambia||0 (5)||0 (5)||0 (5)||0|
- The domestic WHT rate applies unless the DTT rate is lower, in which case the lower DTT rate applies.
- The lower rate applies if the beneficial owner is a company that controls, directly or indirectly, at least 15% of the voting power in the company paying the dividends; otherwise, the higher rate applies.
- The lower rate applies if the recipient is a company that owns at least 25% of the shares of the company paying the dividends; otherwise, the higher rate applies.
- The lower rate applies if the recipient is a company that owns at least 25% of the shares of the company paying the dividends during the six-month period immediately preceding the date of payment of the dividends; otherwise, the higher rate applies.
- The domestic rate applies if income is exempt from tax in Zambia.
- The domestic rate applies in the absence of a rate specified in the DTT.
- Government borrowing: There is an introduction of WHT exemption on payments of interest, fees, and other payments in respect of loans to the government from non-resident banks, financial institutions, and other governments, which have a retrospective effect from 1 June 2017.