On 31 March 2015, officials from Ireland and Zambia signed an income and capital tax treaty. Once in force and effective, the treaty will replace the 1971 income tax treaty between the two countries, which is currently in force.
The treaty covers Irish income tax, universal social charge, corporation tax and capital gains tax. It covers Zambian income tax.
The treaty includes the provision that a permanent establishment will be deemed constituted if an enterprise furnishes services in a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 183 days in any 12-month period.
The following capital gains derived by a resident of one Contracting State may be taxed by the other State:
Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.
Both countries generally apply the credit method for the elimination of double taxation.
The treaty will enter into force once the ratification instruments are exchanged, and will apply from 1 January of the year following its entry into force.
The 1971 income tax treaty between the Ireland and Zambia will cease to have effect on the dates on which the new treaty becomes effective.
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