On 31 December 2020, Zambia has published The Income Tax (Transfer Pricing) (Amendment) Regulations under Statutory Instrument No. 117 of 2020. The Regulations introduce country-by-country (CbC) reporting requirements, which are effective from 1 January 2021.
An ultimate parent entity of a multinational enterprise (MNE) group that is resident for tax purposes in Zambia with an annual consolidated group revenue exceeding EUR 750 million or ZMW 4,795 million in the immediately preceding accounting year shall file a CbC report with the Commissioner-General with respect to its reporting accounting year on or before the date.
A CbC report required by these Regulations shall be filed no later than 12 months after the last day of the reporting accounting year of the MNE group. So the first CbC reporting fiscal year will be 2021 and the first reporting year will be ended on 31 December 2022.
A constituent entity of a MNE group that is resident for tax purposes, in the Republic shall notify the Commissioner-General whether it is the ultimate parent entity or the surrogate parent entity, no later than the last day of the reporting accounting year of the MNE group.
Where a constituent entity of an MNE group that is resident for tax purposes, in the Republic is not the ultimate parent entity or the surrogate parent entity, the constituent entity shall notify the Commissioner-General of the identity and tax residence of the reporting entity, no later than the last day of the reporting accounting year of the MNE group.
