Transfer Pricing: Country-by-Country Reporting Notification and Report filing for the 2021 tax charge year

Due dates
  1. The Country-by-Country Reporting Notification to the Zambia Revenue Authority (ZRA) is due by the end of the accounting year of the Multinational Enterprise (MNE) Group with respect to the 2021 tax charge year.
  2. The Country-by-Country Report (CbCR) filing is due within 12 months after the end of the accounting year of the MNE Group in relation to the 2021 tax charge year.



Country-by-Country Reporting regulations were introduced in Zambia effective 1 January 2021. This means a constituent entity which is not the ultimate parent entity (UPE) of a MNE Group must file the following with the ZRA:

  1. A Country-by-Country reporting Notification
  2. A Country-by-Country Report


Conditions for an entity to qualify for filing

  • The MNE Group consolidated turnover for the year is at least ZMW4.795 billion;
  • The constituent entity for tax purposes is resident in Zambia;
  • One of the following conditions apply:
    • the UPE of the MNE Group is not obligated to file a CbCR in its State of tax residence;
    • the State in which the UPE is resident for tax purposes has a current international agreement with the Zambia but does not have a qualifying competent authority agreement with Zambia for filing the CbCR for the reporting accounting year; or
    • there is a system failure in the State of tax residence of the UPE and the Commissioner- General notifies the constituent entity resident for tax purposes in Zambia.
Note that the CbCR requirements are prescribed in the regulations.
You are therefore advised to be fully compliant with all the CbCR filings to avoid non-compliance penalties.
For more information or assistance, please contact us:

Michael Phiri

Director & Partner, Tax

KPMG Zambia 


Benson Mubanga

Associate Director, Tax

KPMG Zambia