{
  "url": "https://openlegislation.uk/double-taxation-relief-taxes-on-income-zimbabwe-order-1982/note",
  "json_url": "https://openlegislation.uk/double-taxation-relief-taxes-on-income-zimbabwe-order-1982/note.json",
  "legislation": "uksi/1982/1842",
  "legislation_title": "The Double Taxation Relief (Taxes on Income) (Zimbabwe) Order 1982",
  "legislation_url": "https://openlegislation.uk/double-taxation-relief-taxes-on-income-zimbabwe-order-1982",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "Under the Convention with Zimbabwe scheduled to this Order certain trading profits not arising through a permanent establishment (Article 7) and the earnings of temporary business visitors (Articles 14 and 15) are, subject to certain conditions, to be taxed only in the country of the taxpayer's residence. Where an enterprise which is a resident of one country carries on business through a permanent establishment in the other, the profits of the enterprise which are attributable to that permanent establishment may be taxed in that other country (Articles 5 and 7). Shipping and air transport profits are to be taxed only in the country in which the place of effective management of the enterprise is situated (Article 8).\nIncome derived by public entertainers from their personal activities may normally be taxed in the country in which those activities are exercised (Article 18). Renumeration and pensions for government service are normally to be taxed by the paying Government only (Article 20) while other pensions paid in respect of an employment exercised in one country and arising from a source in that country are taxable only in that country (Article 19). Certain payments made to visiting students and business apprentices are, subject to certain conditions, to be exempt in the country visited (Article 21).\nIncome from immovable property (Article 6) and capital gains (Article 14) arising from the disposal of such property or of shares in a company whose assets consist mainly of such property may be taxed in the country in which the property is situated. Capital gains arising from the disposal of movable property are normally to be taxed only in the country of the taxpayer's residence unless they arise from the disposal of assets of a permanent establishment or a fixed base which the taxpayer has in the other country (Article 14).\nWhere a United Kingdom company pays a dividend to a resident of Zimbabwe (other than to a company which controls 10 per cent or more of the voting power in the paying company), the recipient will, subject to certain conditions, receive the tax credit to which an individual resident in the United Kingdom would be entitled, less tax at a rate not exceeding 20 per cent on the aggregate of the dividend and the tax credit. Where dividends are paid by a Zimbabwean company to a resident of the United Kingdom the tax charged in Zimbabwe is not to exceed 5 per cent where the dividends are paid to a company which controls at least 25 per cent of the voting power in the company paying the dividend and 20 per cent in all other cases (Article 10).\nThe rate of tax to be imposed by the country of source on interest (Article 11), royalties (Article 12) and technical fees (Article 13) paid to a resident of the other country is, in general not to exceed 10 per cent. The country of source will exempt from tax interest payable to the Government (or government agency) of the other country and interest arising in Zimbabwe on loans guaranteed by the United Kingdom Export Credits Guarantee Department will be exempt from tax in Zimbabwe (Article 11).\nWhere income continues to be taxable in both countries relief from double taxation is to be given by the country of the taxpayer's residence (Article 23).\nThere are also provisions for the exchange of information and consultation between the competent authorities of the two countries (Articles 25 and 26) and for the safeguarding of nationals and enterprises of one country against discriminatory taxation in the other. An additional tax not exceeding 2½ per cent, however, may be charged on profits earned in one country by a permanent establishment of a company which is a resident of the other (Article 24).\nThe Convention is to take effect in the United Kingdom from April 1981 (Article 28).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/1982/1842/note",
    "retrieved_at": "2026-10-29T18:09:40.080780+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}