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Corporate - Withholding taxes
Last reviewed - 02 January 2024WHT rates
| Payment | WHT (%) | |
| Resident | Non-resident | |
| Dividend: | ||
| 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 |
| Otherwise | 10 | 10 |
| Interest | 10 | 10 |
| Rent: | ||
| Land and buildings | 10 | 10 |
| Aircraft lease | 10 | 10 |
| Other assets | 0 | 10 |
| Royalty* | 15 | 15 |
| Natural resource payment | 15 | 15 |
| Service fees | 5 | 15 |
| Director fees (other than full time service) | 15 | 15 |
| Insurance premium | 0 | 5 |
| 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 |
* If payment relates to use of cinematography film, video tape sound recording, or any other like medium, the applicable rate is 10%.
Double tax treaty (DTT) rates
| Recipient | WHT (%) | |||
| Dividend | Interest (8) | Royalties | Management / technical fees | |
| Domestic rate (1) | 10 | 10 | 15 | 15 |
| Treaty: | ||||
| Canada | 20/25 (2) | 15 | 20 | 20 |
| Denmark | 15 | 12.5 | 20 | 20 |
| Finland | 20 | 15 | 20 | 20 |
| India | 5/10 (3) | 10 | 10 | 0 |
| Italy | 10 | 15 | 15 | 15 (6) |
| Norway | 20 | 15 | 20 | 20 |
| South Africa | 10/20 (2) | 10 | 10 | 15 (7) |
| Sweden | 15/25 (4) | 15 | 20 | 20 |
| Zambia | 0 (5) | 0 (5) | 0 (5) | 0 |
Notes
- 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.
- The DTA does not have a management, technical, or service fee article. WHT is still usually deducted.
- 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.
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