The early years

This chapter complements the previous one by considering the other end of negotiations, in a lowerincome country. One of the few negotiations between the UK and a lowerincome country during the 1970s that was initiated by the lowerincome country itself was the 1972 treaty with Zambia. In comparison with other agreements signed by the UK at the time, this was an easy negotiation for the UK, in which Zambia did not gain an outcome that protected many of its source taxing rights. Zambia permits us a withincase comparison, by looking at two dif ferent time periods: the 1970s, when Zambia was an enthusiastic negotiator, and the 2000s and 2010s, when it was not. This first UK agreement was part of a flurry of negotiations at the beginning of the 1970s, and during that de cade Zambia signed ten tax treaties, with countries of Western Eu rope and Japan. No other subSaharan country signed as many: Kenya and Tanzania, the next closest by number of signatures, signed six each.1 Yet as figure 6.1 shows, on average, Zambia’s early 1970’s treaties imposed far greater restrictions on its source taxing rights than those signed by other African countries, and also Zambia’s later treaties. In Zambia in the 1970s, a context where nobody in the bureaucracy had a detailed knowledge of international tax, the tax treaties myth took hold, but without the commensurate negotiating capability. The large tax revenue from Zambia’s mining industry during the early 1970s meant that the tax costs of the treaties Zambia was negotiating were less impor tant to those driving the negotiations. In contrast, from democ ratization in 1991 until the Movement for Multiparty Democracy (MMD) fi nally lost power in 2011, a period when subSaharan 6 ZAMBIA