Direct Tax Avoidance Agreements

Zambia

ARTICLE 19 - Governmental functions - 1. Remuneration paid by or out of funds created by a Contracting State, a political sub-division or a local authority thereof, to a citizen of that State in respect of an employment shall be taxable only in that State.

2. Any pension paid by or out of funds created by a Contracting State a political sub-division, or a local authority thereof, to any individual may be taxed in that Contracting State.

3. The provisions of paragraph (1) of this article shall not apply to payments in respect of services rendered in connection with any business carried on by the Government or either of the Contracting States for the purposes of profit.

4. For the purposes of this article, the term Government shall include any State Government or local authority of either Contracting State and in particular the Reserve Bank of India and the Bank of Zambia.