Tax Alert Tax Alert Tax Alert

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.

Background

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.