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of <h1>Zambia DTAA Article 14: Management and Consultancy Fees Taxed Up to 10% in Payer's State, with Exceptions</h1> Article 14 of the Double Tax Avoidance Agreement (DTAA) between Zambia and another Contracting State addresses the taxation of management and consultancy fees. These fees, paid to a resident of one Contracting State by a payer in another, may be taxed in the recipient's State, but can also be taxed in the payer's State at a rate not exceeding 10% of the gross amount. The article defines such fees as payments for managerial, technical, or consultancy services, excluding employee payments. Exceptions apply if the recipient has a permanent establishment in the payer's State, in which case Article 7 applies. Special relationship cases may adjust taxable amounts.
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