Zambia

There are no consolidated CIT returns for groups.

Losses in one group company cannot offset profits in another.

Transfer pricing

• Transactions must be at arm's-length. Non-compliance can lead to income adjustments and avoidance penalties.
• Companies must maintain transfer pricing documentation for ten years.
• Non-compliance penalties can reach ZMW 32 million.

International compliance

From 2021, multinationals with revenues over ZMW 4,795 million must submit Country-by-Country (CbC) Reports within 12 months post-financial year.

Zambia joined the OECD Global Forum to combat tax evasion and enhance financial transparency, committing to EOIR and AEOI standards.

Thin capitalisation

• Interest deductibility is limited to 30% of tax EBITDA, excluding turnover tax system businesses and those under the Banking and Financial Services Act.
• Interest deductibility is limited to 70% of tax EBITDA for an SPV operating in the rail sector.

Controlled foreign companies (CFCs)

Zambia does not have a CFC regime.