1. 15 December 2012
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Double Taxation Avoidance Agreement(DTAA) between Mauritius and Zambia
We are pleased to inform about the DTAA between Mauritius and Zambia has entered into force
from June 2012. The below are the effects of DTAA:
In Mauritius
» With regard to income, in respect to any income year beginning or after 1st July 2012
In Zambia
»
With regard to taxes with held at source, in respect of amounts paid or credited on or after
1st August 2012
»
With regard to other taxes, in respect of taxable years beginning on or after 1st August
2012
Till date, a total of 17 DTAAs (out of which 14 have been ratified) and 19 IPAAs have been
signed with African countries. With this growing number of bilateral agreements, Mauritius is
positioning itself as a safe, trusted and well-established international financial centre, while
consolidating its aspirations to be the natural choice of business and investment gateway to
Africa.
The main articles of Mauritius – Zambia are:
Dividend
Withholding tax rate (WHT) under DTAA – 5%/15% (where 5%applies to beneficial owners who
owns at least 25% of the company paying out the dividend/15% applies in other cases)
WHT in Mauritius – Nil
WHT in Zambia – 15%
Interest
Withholding tax rate (WHT) under DTAA – 10%
WHT in Mauritius – 10% (applicable on payment to non residents/no WHT where payment is
being made from a Global Business Company)
WHT in Zambia – 15%
Royalties
Withholding tax rate (WHT) under DTAA – 5%
WHT in Mauritius – 10%/15% (10% on payments to residents/15% on payments to non residents/
No WHT where payment is made from a Global Business Company)
WHT in Zambia – 15%
The Mauritius – Zambia DTAA does not contain a specific Capital Gains Article. But it should be
noted, that no capital gains taxes are imposed in Mauritius – Zambia DTAA.
Further the Mauritius – Zambia DTAA provides for tax sparing credit and this will not dilute any
incentive that has been given in Zambia. Other articles which follows OECD model are in respect
of Mutual Agreement Procedure and Exchange of Information articles.
Intuit Research Team
Intuit Management Consultancy
India Tel: +91 9840708181 Fax: +91 44 42034149
Dubai Tel: +971 4 3518381 Fax: +971 4 3518385
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