THE GOVERNMENT OF THE REPUBLIC OF ZIMBABWE AND THE GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CHINA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
The Government of the Republic of Zimbabwe and the Government of the People's Republic of China,
Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as "the Agreement");
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 local authorities, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.
3. The existing taxes to which the Agreement shall apply are in particular:
(a) in China,
(i) the individual income tax;
(ii) the enterprise income tax;
(hereinafter referred to as "Chinese tax");
(b) in Zimbabwe:
(i) the income tax;
(ii) the non-resident shareholders' tax;
(iii) the non-residents' tax. on fees;
(iv) the non-residents' tax on royalties;
(v) the capital gains tax, and
(vi) the residents' tax on interest;
(hereinafter referred to as "Zimbabwean tax").
4. The Agreement shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any signilicant changes which have been made in their respective taxation laws within a reasonable period of time after such changes.