Direct Tax Avoidance Agreements

Zambia

ARTICLE 16 - Dependent personal services - 1. Subject to the provisions of articles 17, 18, 19, 20, 21 and 22, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such representation as is derived therefrom may be taxed in that other Contracting State.

2. Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if

(a) the recipient is present in the other Contracting State for a period not exceeding in the aggregate 183 days in the fiscal year concerned ; and

(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State ; and

(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State.

3. Notwithstanding the provisions of paragraphs (1) and (2), remuneration in respect of employment exercised aboard a ship or aircraft in international traffic may be taxed only in the ContractingState in which the place of effective management of the enterprise is situated.