Country-by‑Country Reporting – Compilation of 2025 Peer Review Reports

Zambia

Overview of CbC reporting requirements

First reporting fiscal year: Ending on 31 December 2021

Consolidated group revenue threshold: ZMW 4,795 million

Filing deadline: 12 months following the end of the reporting fiscal year

Local filing required: Yes

Surrogate parent entity filing permitted: Yes

First review of domestic legal framework: 2021-2022

Summary of recommendations

 

Area of implementation	Recommendations for improvement
Domestic legal and administrative framework	It is recommended that Zambia take steps to ensure that local filing only occurs in the circumstances permitted under the minimum standard. It is recommended that Zambia clarify that the annual consolidated group revenue threshold calculation rule applies in line with the OECD guidance on currency fluctuations in respect of an MNE Group whose Ultimate Parent Entity is located in a jurisdiction other than Zambia.
Exchange of information framework	It is recommended that Zambia take steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions and with which Zambia has an international exchange of information agreement in effect that allows for the automatic exchange of tax information. It is recommended that Zambia take steps to implement the necessary processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework.
Appropriate use	It is recommended that Zambia take steps to ensure that the appropriate use condition is met ahead of the first exchanges of information.

The domestic legal and administrative framework

Zambia published guidance which removes the Euro filing threshold for CbC reporting and clarifies the threshold as 4,795 million Zambian Kwacha.1

Zambia’s 2021-2022 peer review included a recommendation that Zambia publish the full content and format requirements of the CbC Report. Zambia has published the full content and format requirements of the CbC Report and this recommendation is therefore removed.2

Zambia has a legislative requirement for local filing which is in line with the standard but which is in effect despite Zambia not yet meeting all of the consistency, confidentiality and appropriate use conditions. It is therefore recommended that Zambia take steps to ensure that local filing only occurs in the circumstances permitted under the minimum standard. This recommendation remains in place since the 2021-2022 peer review.

It is recommended that Zambia clarify that the annual consolidated group revenue threshold calculation rule applies in line with the OECD guidance on currency fluctuations in respect of an MNE Group whose Ultimate Parent Entity is located in a jurisdiction other than Zambia. This recommendation remains in place since the 2021-2022 peer review.

The exchange of information framework

Zambia has no bilateral relationships in place for the exchange of CbC reports nor processes to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework.

It is recommended that Zambia take steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions and with which Zambia has an international exchange of information agreement in effect that allows for the automatic exchange of tax information. This recommendation remains in place since the 2018-2019 peer review.

It is recommended that Zambia take steps to implement the necessary processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework. This recommendation remains in place since the 2018-2019 peer review.

Appropriate use of CbC reports

Zambia does not yet have controls in place to ensure the appropriate use of CbC reports.

It is recommended that Zambia take steps to ensure that the appropriate use condition is met ahead of the first exchanges of information. This recommendation remains in place since the 2018-2019 peer review.

Notes

← 1.  Practice-Notes-2023.pdf - https://www.zra.org.zm/wp-content/uploads/2023/02/Practice-Notes-2023.pdf

← 2. oPractice-Note-No.-2-of-2022-Country-by-Country-Reporting.pdf - https://www.zra.org.zm/wp-content/uploads/2022/07/Practice-Note-No.-2-of-2022-Country-by-Country-Reporting.pdf