Transfer Pricing News Issue 37 - December 2021

2022 budget includes changes to CbCR rules

Zambia’s 2022 budget announced by the Minister of Finance and National Planning on 29 October 2021 includes changes to the country-by-country reporting (CbCR) rules.

If the budget measures are approved, the following amendments to the Transfer Pricing Act would take effect on 1 January 2022:

  • Two new schedules would be introduced for taxpayers to file their CbCR. Taxpayers would have to list the constituent entities of the multinational group aggregated per tax jurisdiction and provide additional information, such as the nature of the constituent entity’s activities;
  • A local currency threshold of ZMW 4.795 billion would be introduced for purposes of CbCR;
  • The transfer pricing regulations would be amended to clarify how the CbCR is to be submitted to the Commissioner General; and
  • The conditions under which a local entity would not be required to file a CbCR would be clarified.

Katrina Mabika