The Government of the Republic of Zambia and the United Arab Emirates desiring to further develop their economic relationship and to enhance their cooperation in tax matters, intending to conclude an agreement for the elimination of double taxation with respect to taxes on income without creating opportunities for non taxation or reduced taxation through tax evasion or avoidance (including through treaty shopping arrangement aimed at obtaining reliefs provided in this agreement for the indirect benefit of residents of third States)
HAVE AGREED as follows:
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income all taxes im...