Switzerland and Zambia signed a new double taxation agreement (DTA) in the area of income taxes on 29 August 2017.
The new DTA replaces the 1954 agreement between Switzerland and the United Kingdom, which previously applied to Switzerland and Zambia.
According to a media release dated 29 August 2017, the DTA between Switzerland and Zambia contains an abuse clause which corresponds to the recommendations of the OECD and G20 Base Erosion and Profit Shifting (BEPS) project, as well as an arbitration clause and an administrative assistance clause in accordance with current international standards on the exchange of information on request. The DTA also contains
- Dividends are taxed at source at a maximum of 15% and dividends from qualifying holdings at a maximum of 5%. A qualifying holding is deemed to exist if the beneficial owner is a company (but not a partnership) that directly holds at least 10% of the capital of the company paying the dividends for a period of 365 days.
- Interest is generally taxed at 10% at source.
The signed agreement is available here and must be approved by the parliaments of both countries before it can enter into force.
