Zambia proposes changes to transfer pricing documentation requirements

By Joseph Jalasi and Mailesi Undi of Eric Silwamba, Jalasi and Linyama Legal Practitioners, Lusaka

On 25 September, Zambia’s Minister of Finance read the 2021 budget to the National Assembly. The government is proposing significant transfer pricing amendments.

The Zambia government proposes to introduce country-by-country reporting for large multinationals operating in Zambia.

Also, the transfer pricing regulations would be modified to reduce the number of companies required to file transfer pricing documentation.

Under current Zambia transfer pricing legislation and regulations, companies with turnover of ZWM 20 million (USD 990,099 ) must file contemporaneous transfer pricing documentation.

The government proposes to increase this annual threshold to ZWM 50 million (USD 2,475,248).

The government also seeks to exempt from transfer pricing documentation filing requirements medium-sized businesses having an annual turnover of ZWM 50 million (USD 2,475,248) that are not multinational enterprises.

Please note that the legislative amendments shall take effect on 1 January 2021.

— Joseph Jalasi is Senior Partner at Jalasi and Linyama Legal Practitioners, Lusaka.

— Mailesi Undi is an associate at Jalasi and Linyama Legal Practitioners, Lusaka.

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