Rates last updated: 27 October 2026 · How we verify
🇿🇲🇧🇼 Ireland's Tax Treaties with Zambia and Botswana: Who Taxes Your Salary, Property and Pension
454 Botswana citizens and 133 Zambian citizens were living in Ireland at the 2022 census (CSO, table F5065), small communities with something most African communities here don't have: a tax treaty in force. Both treaties are modern, both cover USC, and on salary they work the same way. On pensions they point in opposite directions, which matters most to anyone who plans to retire home, and the Botswana treaty has a clause that limits its relief for people who aren't Irish-domiciled.
- The Ireland–Zambia treaty has applied since 1 January 2016 and the Ireland–Botswana treaty since 1 January 2017.
- Under both, Ireland taxes your salary for work done here, and the home country can tax rent and gains on its own property, with an Irish credit.
- The difference: Zambia's treaty gives a private pension only to the country you live in, Botswana's lets the country it's paid from tax it.
Under both treaties, dividends and interest from home are capped at low rates. Botswana's treaty also limits its relief to income you bring into Ireland if you're not Irish-domiciled. Neither country taxes an Irish salary, because both tax on a source basis.
Does Ireland have tax treaties with Zambia and Botswana?
- Yes, both are in force: Zambia's from 1 January 2016 (S.I. No. 437 of 2015) and Botswana's from 1 January 2017 (S.I. No. 467 of 2014).
- Zambia's was signed in Lusaka on 31 March 2015, replacing a 1971 convention; Botswana's in Gaborone on 10 June 2014.
- Both cover income tax, USC and CGT, and apply as signed: Revenue publishes no synthesised text with the OECD multilateral instrument (checked October 2026).
- The texts. Revenue publishes the Zambia 2015 convention and the Botswana agreement; dates and statutory instruments are on its dates of effect table. The Zambian 1971 convention, signed in London, ceased to have effect when the 2015 one took effect.
- Six in Africa. With Egypt, Morocco, Ethiopia and South Africa, these are Ireland's six treaties in effect in Africa. Kenya and Ghana are signed but not in effect; see the full list.
- Credits in a non-resident year. Revenue gives personal tax credits to non-residents who are EU citizens or citizens of a treaty country (Revenue). Zambian and Botswana citizens qualify: full credits if all their income is Irish, otherwise a share in proportion to the Irish part. A Nigerian or Sudanese colleague in the same position gets none.
How do the two treaties compare?
- They match on residence, salary and property, and differ on investment rates, technical fees, pensions and remittances.
- Dividends are capped at 5% under Botswana's treaty and 7.5% under Zambia's; interest at 7.5% and 10%.
- Both let the home country tax gains for five years after you leave it.
| Ireland–Zambia (2015) | Ireland–Botswana (2014) | |
|---|---|---|
| Who's resident if both claim you (Art. 4(2)) | Permanent home, then centre of vital interests, habitual abode, nationality, then agreement | Same order |
| Salary for work done in Ireland (Art. 14) | Taxable in Ireland | Taxable in Ireland |
| Dividends from a home company (Art. 10) | Home country may tax at no more than 7.5% | Home country may tax at no more than 5% |
| Interest (Art. 11) | No more than 10% | No more than 7.5% |
| Royalties (Art. 12) | 10% (literary and artistic copyright, films, recordings), or 8% for scientific copyright, patents, trade marks, designs, plans, secret formulas or processes and know-how | 7.5%, or 5% for industrial, commercial or scientific equipment |
| Technical, management or consultancy fees | No separate article | Art. 20: home country may tax at no more than 7.5% |
| Rent and gains on home property (Arts. 6, 13(1)) | Zambia may tax; Ireland credits the Zambian tax | Botswana may tax; Ireland credits the Botswana tax |
| Unquoted shares in property-rich companies (Art. 13(4)) | Zambia may tax if more than 50% of value is Zambian property | Botswana may tax on the same 50% test |
| Gains after you leave (Art. 13(6)) | Zambia may tax for five years after you were last resident there | Botswana may tax for five years after you were last resident there |
| Private pensions and annuities (Art. 17) | Taxable only in the country where you live | May be taxed in the country they're paid from |
| Government service pensions (Art. 18(2)) | Only in the paying country, unless you're resident in and a national of the other | Same rule |
| Remittance clause | None | Art. 23(3): if you're on the Irish remittance basis, Botswana's treaty relief covers only what you bring into Ireland |
Do Zambia and Botswana tax you after you move to Ireland?
- Not on your Irish salary: both countries tax on a source basis.
- The exception is investment income: Botswana taxes resident citizens, and Zambia its residents, on foreign interest and dividends, per PwC (reviewed January and July 2026).
- Rent from a house at home is taxable at home whether or not you're still resident there.
- Botswana. A territorial system: income is taxable in Botswana if its source is in Botswana (PwC Botswana), so pay for work in Ireland isn't Botswana income. The exception is investment income: a resident citizen's interest and dividends from investments made outside Botswana are included in income, foreign dividends at 10% (PwC). Resident rates run from 0% on the first BWP 48,000 to 25% above BWP 156,000. Residence normally turns on a permanent place of abode in Botswana and on presence of 183 days in the tax year or the previous one (PwC).
- Zambia. Source-based, but Zambian residents are also taxed on interest and dividends from outside Zambia (PwC Zambia). For 2026, 0% up to ZMW 61,200 and 37% above ZMW 110,400. You're treated as resident unless you're in Zambia only for a temporary purpose, and anyone present for 183 days in a charge year is resident (PwC). Interest on an Irish account while you're still Zambian (or, as a citizen, Botswana) resident is the item to watch; the treaty caps it and gives credit.
- Irish residence is a day count: 183 days in the tax year, or 280 over this year and last with more than 30 this year (Revenue). In your arrival year you can choose to be resident if you'll be resident the next year. If both countries call you resident, the Article 4 tie-breaker decides, and a home, job and family in Ireland usually settle it here.
What about a house, shares and savings back home?
- Ireland taxes them as they arise if you're Irish-domiciled, or when you bring the money into Ireland if you're not, and credits the home-country tax.
- Under the Botswana treaty, if you're not Irish-domiciled, the caps and relief follow only the money you bring in; Zambia's treaty has no such clause.
- Rent. Taxable at home as the property's country. Ireland taxes the net rent if you're Irish-domiciled, or rent brought in, with no deductions, if you're not (Revenue); the home-country tax is a credit. See foreign rental income.
- Selling a property or unquoted property company shares. The home country may tax the gain; Ireland charges CGT at 31% (from 7 October 2026) on the gain if you're Irish-domiciled, or on the gain to the extent the proceeds are brought into Ireland if you're not, with credit for the home-country tax. See our CGT guide.
- Dividends and interest. Give the payer evidence that you're Irish resident (Revenue issues a Letter of Residence through myAccount) so it applies the treaty rate rather than its domestic withholding; Botswana's domestic rates for non-residents are 10% on dividends and 15% on interest (PwC), against 5% and 7.5% under the treaty.
- The Botswana remittance clause. Article 23(3) works like the South African one: if Ireland taxes you only on what you bring in, Botswana's treaty relief applies only to that amount, so dividends you leave in Botswana can be taxed at Botswana's full domestic rate. Our South Africa treaty guide works an example, and the remittance basis guide explains what counts as bringing money in.
Who taxes your pension if you retire to Zambia or Botswana?
- Under the Zambian treaty a private occupational pension, PRSA or annuity is taxable only where you live, so an Irish one can be paid tax-free under a PAYE Exclusion Order.
- Under the Botswana treaty the paying country may tax it, so Ireland keeps taxing an Irish pension paid to a resident of Botswana.
- Government service pensions stay taxable in Ireland under both, unless you're resident in and a national of the other country.
- Zambia, Article 17. Pensions for past employment and annuities paid to a resident of a country "shall be taxable only in that State". Revenue's manual 42-04-01, section 6.2, says a PAYE Exclusion Order should issue where a treaty relieves an occupational pension from Irish tax; the scheme paying it applies (section 3.2), with proof of your Zambian tax residence. Because Zambia taxes on a source basis, it may not tax a foreign pension either; check with a Zambian adviser.
- Botswana, Article 17. Pensions and annuities arising in one country and paid to a resident of the other "may be taxed" in the country they arise in. Ireland keeps its right, so no Exclusion Order, and with Botswana's territorial system Botswana is unlikely to add tax of its own; check with a Botswana adviser.
- The Irish State Pension. Neither treaty has a separate social security article, and Revenue doesn't treat social welfare pensions as government pensions (manual 42-04-01, section 6.3). Under Zambia's, the State Pension most likely follows Article 17 or the Other Income article, both of which give it to the country where you live; under Botswana's it depends on the article: if it counts as a pension for past employment, Article 17 lets Ireland keep taxing it; if not, the Other Income article (Article 21) gives it only to Botswana. It's paid without tax deducted either way, so ask Revenue for a ruling before you rely on it.
- A private Zambian or Botswana pension paid to you in Ireland. Under the Zambian treaty, taxable only in Ireland. Under the Botswana treaty, Botswana may tax it and Ireland taxes it as a resident's income (on what you bring in if you're not Irish-domiciled), with credit for the Botswana tax. A Zambian or Botswana government service pension stays taxable only at home unless you're an Irish national.
Worked example: one Irish pension, two retirements
- Chanda retired to Lusaka and Kagiso to Gaborone at the end of 2025, each with the same €40,000-a-year Irish occupational pension and no other income.
- Kagiso pays €4,000 of Irish income tax on it; Chanda, with a PAYE Exclusion Order under the Zambian treaty, pays €0 in Ireland.
Starting data (assumptions): both worked for a private-sector Irish employer and draw a €40,000 pension from its occupational scheme; neither has a public service pension. Chanda is a Zambian citizen and Kagiso a Botswana citizen; both are 60, single, non-resident in Ireland for all of 2026 and resident in Zambia and Botswana respectively, with no other income anywhere. As citizens of treaty countries with only Irish income, both get the full 2026 single credits (€2,000 personal and €2,000 employee) and the €44,000 standard rate band. USC isn't included (Kagiso would owe USC on the pension too; the Zambian treaty also covers USC), and neither is any Zambian or Botswana tax.
| Kagiso, resident in Botswana | Chanda, resident in Zambia | |
|---|---|---|
| Treaty rule (Art. 17) | Ireland may tax | Taxable only in Zambia |
| Irish tax at 20% (all within the €44,000 band) | €40,000 × 20% = €8,000 | Not charged under the Exclusion Order |
| Less personal and employee credits | −€4,000 | — |
| Irish income tax for 2026 | €4,000 | €0 |
If the pension were a civil service pension instead, the answer would be the same for both: under Article 18(2) of each treaty a government service pension is taxable only in the country where you live if you're resident in and a national of that country, as Chanda and Kagiso are. An Irish national retiring to Lusaka or Gaborone would keep paying the €4,000 in Ireland. Chanda's Exclusion Order isn't automatic: until it's in place, the scheme deducts Irish tax under PAYE, and the overpayment is reclaimed on a return. If Chanda later moved back to Ireland, the pension would be taxable here again.
What Revenue actually asks for
- While you live in Ireland, declare Zambian or Botswana income Ireland taxes on your Irish return and claim the credit for the home-country tax.
- Keep the assessment or withholding statement for that credit.
- When you retire home, ask your pension scheme to apply for a PAYE Exclusion Order if the treaty gives your pension to your new country.
- Letter of Residence: request it in myAccount so a Zambian or Botswana payer applies the treaty rate on dividends and interest.
- Declare home-country income Ireland taxes (all of it if you're Irish-domiciled, what you brought in if you're not) on Form 12 if taxable non-PAYE income is €5,000 or less and gross non-PAYE income €30,000 or less, otherwise Form 11, and claim the treaty credit.
- Keep the home-country tax evidence and, on the remittance basis, records showing what you brought into Ireland.
- Retiring home to Zambia: ask the scheme paying your private occupational pension to apply to Revenue for a PAYE Exclusion Order, and give it proof of your Zambian tax residence (for example a residence certificate from the Zambia Revenue Authority); claim back any Irish tax deducted before it took effect.
- Claim your Irish credits for every open year while you're here; 2022 closes on 31 December 2026.
Where do you start?
If you're planning to retire home, check which treaty applies and whether your pension is private or public service before you go: that one line decides whether Ireland keeps taxing it. If you're still working here, get a Letter of Residence so the treaty rates apply to dividends and interest from home.
Related reading
- Ireland–South Africa tax treaty: the other remittance clause
- Morocco: the treaty that sends private pensions to where you live
- Leaving Ireland: the refund and Split Year Treatment
- Foreign rental income: a house back home and Irish tax
- The remittance basis for non-domiciled residents
- Ireland's double tax treaties: the full country list
- Tax guides by nationality
Questions we get asked
Is there a double tax treaty between Ireland and Zambia?
Yes. A new convention signed in Lusaka on 31 March 2015 has applied in Ireland since 1 January 2016 and replaced the 1971 convention. It covers income tax, USC and CGT.
Is there a double tax treaty between Ireland and Botswana?
Yes. It was signed in Gaborone on 10 June 2014 and has applied in Ireland since 1 January 2017. It covers income tax, USC and CGT, and includes a remittance clause for people on the Irish remittance basis.
Will Zambia or Botswana tax my Irish salary?
Normally not. Both tax on a source basis, so pay for work done in Ireland isn't income from Zambia or Botswana; Zambia taxes its residents, and Botswana its resident citizens, on foreign interest and dividends. Under both treaties, salary for work in Ireland is taxable in Ireland.
If I retire to Zambia, is my Irish pension taxed in Ireland?
A private occupational pension, PRSA or annuity is taxable only in Zambia under the treaty once you're resident there, and Revenue can issue a PAYE Exclusion Order. A public service pension stays taxable in Ireland unless you're also a Zambian national. Under the Botswana treaty, Ireland keeps taxing an Irish occupational pension or annuity.
Do Zambian and Botswana citizens get Irish tax credits in a year they're not resident?
Yes, because both countries have a treaty in force: full credits if all your income is Irish, otherwise a share in proportion to the Irish part of your total income.