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 announces the denunciation of the double taxation agreement with Mauritius. The Zambian cabinet approved the end of the DBA between Zambia and Mauritius. 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. For more information on this warning, please contact: The contract came into effect on June 15, 2012 and includes revenue 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%) 2.2.2.2 And royalties (5%). Ernst and Young Law Society, Pan African Tax – Transfer Pricing Desk, Paris In a memorandum issued after the cabinet meeting on 22 June 2020, the Zambian government announced that the Double Taxation Agreement (DBA) between the Government of the Republic of Zambia and the Government of the Republic of Mauritius would end on 31 December 2020. ——————————————— CONTACT . 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. Ernst – Young Advisory Services (Pty) Ltd., Africa ITTS Leader, Johannesburg Ernst – Young LLP (UK), Pan African Tax Desk, London The DBA between Zambia and Mauritius requires parties to terminate the termination by June 30 of the calendar year, provided the contract has been in effect for at least five years.