Living in Zambia: 183-day residency requirement as stipulated in the law, foreign access to land, 1950 convention

This page reports on information published by the Zambia Revenue Authority (ZRA), the Zambian Parliament, the Zambia Development Agency (ZDA), and the French tax authorities. According to the Income Tax Act published by Parliament, an individual is treated as a resident for a tax year if they have resided in Zambia for 183 days, except for temporary stays without the intention of establishing permanent residence. This text is a version whose list of amendments ends in 1997. The ZRA specifies a tax of 5 % on the transfer of land or shares. The current salary tax rates are not detailed here.

France applies to Zambia a convention of December 14, 1950, supplemented by exchanges of letters in 1963, which concerns income tax.

Tax residence: Section 4 of the Income Tax Act

The text of the Income Tax Act (Chapter 323) published by the Parliament of Zambia contains the following provisions. The copy does not bear a publication date, and its list of amendments ends with Act No. 3 of 1997; subsequent amendments are not included. The current text can be found on the ZRA website.

• Article 4(1): An individual is not treated as a resident if they are in Zambia for a temporary purpose only, without any intention of establishing residence there, and if they have not resided there, in one or more periods, for the equivalent of 183 days in the tax year ('charge year'). If they reside there for that period, they are treated as a resident for that year.
• Article 4(3): A person other than a natural person is resident when the control and management of their business is exercised in Zambia.
• Article 14(1): Tax is payable, at the rates of Part III of the Charging Schedule, on income from Zambian sources and, for any person ordinarily resident in Zambia, on interest and dividends from foreign sources.

The ZDA states that income is taxed according to the source principle, or the deemed source principle in certain cases, and that non-residents are normally taxed on their Zambian-source income. The text does not define "ordinarily resident.".

Payroll tax and deadlines

The current payroll tax (PAYE) scale is not detailed here: it can be found on the ZRA PAYE calculator, which does not indicate, on the page, the year to which it relates.

The ZRA's "General Tax Information" page, which is undated, states that the employer must remit the withheld tax to the ZRA by the 10th of the following month. Annual income tax returns, along with financial statements, must be filed by June 21st of the following year, which is also the date on which the tax balance is due. Withholdings are remitted by the 14th of the following month. The provisional tax is paid in four installments:

Dividends, interest and royalties

Withholding tax rates on dividends, interest, and royalties are not detailed here; they can be found on the ZRA website. Domestic capital gains tax, rental income tax, and local property taxes are also not detailed.

Real estate: transfer tax and foreign access to land

The ZRA's "General Tax Information" page indicates a property transfer tax. The page is undated; the rates should be confirmed with the ZRA.

For a transfer to a spouse, child, adopted child, or child of the spouse, the value used is the price actually received by the transferor. The page also lists exemptions, including those for the Zambian state, local authorities, registered trade unions, registered pension funds, and registered charities.

The Lands Act (Act No. 29 of 13 September 1995, Chapter 184), in the text published by Parliament, provides in section 3(3) that the President may grant land to a non-Zambian in eleven listed cases, including permanent residents, registered investors, and holders of the President's written consent; holding conditions apply to companies and cooperatives. The term does not exceed 99 years, except under the specific conditions of section 3(6). According to section 5(1), no one may sell, transfer, or dispose of land without the President's consent, which is deemed granted if no decision is made within 45 days (section 5(2)). The text read does not contain a limit on land area and mentions an amendment to section 31 by Act No. 20 of 1996; subsequent amendments are not detailed here.

Inheritance, gifts and special regimes

Inheritance and gift taxes, wealth tax, and regimes reserved for new residents or foreign retirees are not detailed here. For investors, the ZDA indicates that foreign investors can hold 100 % shares in a company registered in Zambia, the main legislation being the Investment, Trade and Business Development Act No. 18 of 2022. It outlines incentives for investments of at least USD 500,000 in priority areas or sectors (zero tariffs on equipment for five years, accelerated depreciation) and, for USD 250,000, facilitated immigration permits, licenses, land acquisition, and services. These provisions apply to business projects, not to individuals.

The France-Zambia Convention: text of 1950, annex of 1963

The BOFiP (Official Bulletin of Public Finances) lists, for Zambia, the convention of December 14, 1950 (former Franco-British convention, published in the Official Journal of August 20 and 21, 1951) and two exchanges of letters, dated November 5, 1963 (Official Journal of December 15, 1963) and December 31, 1963 (Official Journal of February 26, 1964). The list, in force as of January 1, 2026 (version of April 29, 2026), indicates income tax as the tax concerned.

Details of the articles, which in their original wording apply to the United Kingdom and the Federation of Rhodesia and Nyasaland, and how they apply to Zambia are available on our page dedicated to the France-Zambia convention. Departure from France falls under the...’exit tax and tax residence.

What this page does not cover

It does not detail the salary tax scale, the definition of "ordinarily resident," withholding taxes on dividends, interest, and royalties, amendments to the Income Tax Act and the Lands Act subsequent to the cited legislation, domestic capital gains tax, inheritance tax, social security, or residence permits. These matters fall under Zambian law and should be verified with the Zambia Revenue Authority (ZRA). Balmont Conseil is neither a law firm nor a local tax advisor; local tax matters should be verified with a professional based in Zambia. French matters, particularly the departure declaration and the accounts to be declared, are addressed in our pages on tax residency and exit tax.

What changes depending on your situation

• Your number of days of presence in Zambia during the tax year, and the intention to establish or not establish your residence there.
• The nature of your income: salary, dividends, interest, royalties, rent.
• The property in question (land, shares, mining rights) and your status under the Lands Act.
• Your residency situation in France and Zambia, year by year.

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