Zambia provides greater transfer pricing certainty for its taxpayers
In April 2018, with the assistance of the ATAF International Taxation team, Zambia released new transfer pricing Regulations to supplement its existing legislation and regulation. The new Regulations provide rules on a wide range of transfer pricing issues such as the use of the most appropriate transfer pricing method and specifying the documentation taxpayers must maintain to demonstrate their transfer pricing complies with the law.
Last week the Zambia Revenue Authority
(ZRA) published its Transfer
Pricing Practice Note 02/2018. The Practice Note sets out the Commissioner-General’s
interpretation of Zambia’s transfer pricing rules and describes the changes
introduced through the Income Tax (Transfer Pricing) (Amendment) Regulations,
Statutory Instrument No. 24 of 2018.
As noted in the ZRA Practice Note the illustrations
and examples used in this Practice Note are taken form the from the ATAF Suggested Approach to Drafting Transfer
Pricing Practice Notes
. If you are an ATAF member and your country faces tax loss risks from
ineffective transfer pricing rules our International Taxation team is here to
help you introduce new effective rules based on our Suggested Approach to Drafting Transfer Pricing Legislation
and
the ATAF
Suggested Approach to Drafting Transfer Pricing Practice Notes
which will
published in the very near future.
Please feel free to contact the ATAF team on.
Telephone: +27 12 451 8800
E-Mail: info@ataftax.org
