Zambia published the income tax (transfer pricing) (Amendment) regulations under Statutory Instrument No. 24 of 2018 in the official gazette on 6th April 2018. The 2018 regulations conduct transfer pricing transactions between related entities as well as documentation requirements.
According to the draft regulation issued in October 2017, taxpayers whose annual net turnover and other income have reached or exceeded 20 million ZMW in the previous year of assessment must submit a transfer pricing documentation. Under the amendments, the threshold of ZMW 20 million (approximately $ 2.1 million) is not applicable to multinational enterprises (MNEs), effectively rendering all MNEs subject to transfer pricing requirements. Additionally, the general transfer pricing documentation, taxpayers must also maintain additional documentation that must be prepared by the tax return deadline that includes the components of the Master file and Local file as developed as part of BEPS Action 13.
