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Switzerland and Zambia sign new double taxation agreement

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Switzerland and Zambia signed a new double taxation agreement (DTA) in the area of taxes on income.

It replaces the agreement between Switzerland and the United Kingdom of 1954 which up to now applied to Switzerland and Zambia and will create legal certainty conducive to the further development of economic ties between the two countries.

In particular, the new agreement makes provision for dividends being taxed at source at a maximum rate of 15% and qualified participations being taxed at no more than 5%.

With regard to interest, the withholding tax rate is generally 10% and for taxes the rate is 5%.

In addition, the new agreement contains an abuse clause in accordance with the recommendations of the Organisation for Economic Co-operation and Development (OECD) and G20 project to combat base erosion and profit shifting (BEPS project).

Legal certainty will also be increased for taxpayers with the inclusion of an arbitration clause.

The DTA contains an administrative assistance clause in accordance with the current international standard for the exchange of information upon request.

The cantons and the business circles concerned have welcomed the conclusion of the new agreement.

In order to enter into force, it has to be approved by Parliament in Switzerland.

23 COMMENTS

  1. Can someone who understands this explain in simple English what this means, giving examples of usage then indicate who is affected and show where this departs from what was obtaining before and where benefits will accrue for the involved, if any.

  2. Its how swiss companies and individuals will be taxed here and reciprical for all thise zambian companies that are in Switzerland , i think

  3. Please don’t keep us in the dark ,plainly explain ,is this about Mopani or something else because elsewhere we here Switzerland for Glencoe have come on behalf of Mopani!

    • I think this is a good move. what it means is e.g. Copper is now costing $6500 p/t so that tax will apply on that amount here in Zambia.
      Thats how i understand it.

    • Simply says signed a new double taxation agreement (DTA) in the area of taxes on income….most Global Companies sell their products to a subsidiary company based in a tax heaven before the say to the Swiss …it a bit vague!!

  4. How is this helping in reducing transfer pricing…you mean to tell me the Swiss have decided to reduce the tax for us given that they are the biggest exporter of copper ….please articulate in your article..dont just publish gibberish!!

  5. Can some one please explain this agreement – in particular WHAT IS IN IT FOR US ZAMBIANS! I hope this is not another case of Muzungu ani konde Zambians signing things which do not benefoit us. I really pray that we can get to a point where the only documents Zambians put a signature to are ones which benefit us in the long run.

  6. You claim to be educated and yet failing to understand a simple logic of tax. Stay with your little knowledge. You thought by insulting others you are smarter than them. Kikiki

  7. HH oval head knows the benefits for zambia, which he will e able to explain, because his PF government signed the deal.sorry maybe I should have said MMD/PF government, either way the know all will enlighten all bloggers
    Thank you in advance Oval Head. Being in Australia you ll know their slang. Richard Cranium suits you better

  8. Switzerland has been circumventing the tax dues on our copper with the curtail mining companies by accepting imported “Unfinished” copper then headed to China as “pure” benefiting in the mineral costs at the expense of Zambia! That is why Mopani must never be excused!

  9. @Masalamuso #9, HH sold the mines at a song with his colleagues and got benefits! That is why he is rich, very rich today! The “katel” are still behind him today! Got it?

  10. Good one PF, Mopani is fixed now. Next move they must introduce tax for exporting raw mineral materials for example copper concentrates, copper anodes and copper anode slimes at 25% of the contained metals value, this is will promote value adding and beneficiation companies to be set up locally that will create employment. Introduce now a new mining charter as well like what South Africa, Zimbabwe, Botswana and Namibia has done including DRC, all mines must surrender ownership of 25% to the Zambians private investors, Executive leadership must be composed of 50% black Zambians and 95% at middle management level, mining suppliers and contractors must be 80% Zambian and 80% of contract values must be awarded to Zambian companies owned by indigenous Zambians. I sign off. Africa for…

  11. @ Babylon, that is very progressive! I didn’t expect someone in Babylon to give that great contribution! Kekekeke

  12. Sharon you non intelligent input at 12 again shows that you are incapable of evaluating a topic. Your obsession with bringing every topic back to HH only leads one to believe that you are a paid blogger for the MMD/PF regime.
    Your confederate HH OVAL HEAD has been unable to enlighten all of us with his analysis of the doubke tax agreement even though he intimated his knowledge was superior to others.

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