France-Zambia tax treaty: a 1950 text implemented through the exchange of letters in 1963

For Zambia, the administrative list of conventions includes the convention of December 14, 1950, known as the "old Franco-British convention," and two exchanges of letters from 1963. This is the same text as for Malawi: the note at the beginning of the published document specifies that it "continues to have effect only in the relations between France and Malawi and Zambia." The common articles (royalties, earnings, 183 days, pensions, denunciation) are described on our France-Malawi page. This page deals with the specific provisions for Zambia.

Three lines in the list, no BOFiP page

List BOI-ANNX-000306 (April 29, 2026, agreements in force on January 1, 2026) contains three lines for Zambia, without amendment or note:

The tax in question is income tax. Zambia is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511). The BOFiP comment address tested for Zambia (BOI-INT-CVB-ZMB) returns "Document not found": there is no specific policy page for Zambia.

How the text targets Zambia

The published document is entitled "Convention between the President of the French Republic and Her Majesty the United Kingdom for the Avoidance of Double Taxation and Fiscal Evasion with respect to Taxes on Income." The name "Zambia" appears only in the introductory note. The body of the convention and the exchange of letters from 1963 refer to the United Kingdom, the Federation of Rhodesia and Nyasaland, and, in the letter of December 31, 1963, to "Southern Rhodesia, Northern Rhodesia and Nyasaland.".

The 1963 annex stipulates that the term "United Kingdom" should be interpreted as referring to the Federation, unless otherwise specified, for taxes due for 1962 and subsequent years. The texts consulted do not detail how the administration applies these terms to Zambia; this point should be verified with them before any decision is made.

Maximum detention limits and key rules specific to Zambia

Article 20 deals with the elimination of double taxation. Its details are not included here, as the text was drafted for the United Kingdom.

What this page does not cover

It does not provide any Zambian tax rates: this point is not detailed here and falls under Zambian legislation, which should be verified with the Zambia Revenue Authority. It also does not address inheritance, social security, or residency permits. Local tax matters should be verified with a professional based in Zambia. French tax law is covered in our pages on tax residency and exit tax.

What changes depending on your situation

• Reading the terms "United Kingdom" and "Federation" as applied to Zambia.
• The nature of the income: dividend, royalty, pension, private or public remuneration.
• Capital holding and its duration, for a dividend.
• The number of days spent in each state during the tax year.

The rule depends on your situation. No results are guaranteed.