Profits attributable to a branch would be calculated based on a branch's functions, assets, and risks in relation to activities in Zambia, and a transfer pricing benchmarking study may be required to determine the attributable profit margins earned by comparable independent companies, which would inform what level of branch profits would then be subject to CIT in Zambia.
In general, both Zambian resident companies and Zambian branches are required to prepare financial statements in accordance with International Financial Reporting Standards (IFRS). The accounting profit is adjusted to determine taxable profits for each source of income using the same rules applicable for determining taxable income of Zambian resident companies. The normal CIT rate is 30%. However, business in certain industry sectors may be subject to different CIT rates. The CIT rates applicable are described in the Taxes on corporate income section.
WHT applies on profits repatriated by branches of foreign companies at the rate of 20%. On the repatriation of branch profits, relief from double taxation under tax treaties may not be available.