d. If he is a national of the two contracting states or one of the two contracting states, the competent authorities of the contracting states resolve the matter by mutual agreement. 4. The competent authorities of the contracting states may communicate directly with each other in order to reach an agreement in accordance with the preceding paragraphs. If it is desirable to exchange views, such an exchange of views may take place through a commission made up of representatives of the competent authorities of the contracting state. (3) Nothing in this article should be construed to require a contracting state to grant personal allowances, tax breaks and reductions to persons who are not domiciled in that state. The DBA between Zambia and Mauritius obliges the contracting parties to terminate the whistleblowing until 30 June of the calendar year, as long as the contract has been in force for at least five years. Once the notice is issued, the contract will no longer apply to Zambia on the last day of the calendar year and to Mauritius on July 1 of the following calendar year. c.
the term “person” refers to individuals, corporations and all other entities that are considered taxable units under the tax legislation in force in the relevant contracting states; 3. The competent authorities of the contracting states try to resolve by mutual agreement any difficulty or doubt concerning the intermediate situation or the application of the convention. They can also consult with each other to eliminate double taxation in cases that are not under the convention. Zambia has no totalization agreements. In order to conclude an agreement to avoid double taxation and to prevent income tax evasion. The Zambian cabinet approved the end of the DBA between Zambia and Mauritius. With regard to the 2016 ratification law on international conventions (the law), the DBA falls under the category of “bilateral treaties” and does not require ratification by Parliament, unlike “international agreements”. It is therefore not necessary to ask Parliament to terminate the treaty. The termination procedure defined by the DBA itself applies. 3. Notwithstanding the provisions of paragraph 2 of this article, interest that arises in a contracting state and is paid to the government of the other contracting state or its territory is exempt from the tax of the central bank of that other contracting state or of any entity 100% owned by the latter contracting state.
The competent authorities of the contracting states may, by mutual agreement, determine any other state body to which this paragraph applies. and in both cases, conditions different from those that would be achieved between independent companies are imposed or imposed between the two companies in their commercial or financial relations, so that any profits that would be paid to one of the companies, but which have not accumulated as a result of these conditions, can be included in the profits of that business and be taxed accordingly. 2. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other contracting State where the objection appears to be well founded and is unable to find an appropriate solution to resolve the matter by mutual agreement with the competent authority of the other contracting State, in order to avoid taxation that is not in accordance with the convention.