Zambia strengthens its transfer pricing rules

African Tax Administration Forum • April 16, 2018

African tax administrations report that transfer pricing represents one of the highest risks to their tax bases. According to the United Nations Economic Commission for Africa the continent is losing approximately USD50 billion a year in illicit financial flows. Abusive transfer pricing practices is one of the primary sources of these losses.

Having effective transfer pricing legislation is a key element in African countries’ fight to combat abusive transfer pricing practices and is also important in providing taxpayers with greater tax certainty and encouraging voluntary compliance.

With the assistance of the ATAF International Taxation team, Zambia has now released new transfer pricing regulations to supplement its existing legislation and regulations. 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.

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 .


Please feel free to contact the ATAF team on +27 12 451 8800 or info@ataftax.org

  • For more information on ATAF click here .

By ATAF Communication April 29, 2025
The ATAF Model Tax Agreement serves as a guiding instrument to help African nations negotiate treaties that better protect their interests, ensure fair allocation of taxing rights, and enhance domestic revenue mobilisation.
By ATAF Communication April 23, 2025
CEMAC and ATAF agreed to explore practical avenues for cooperation, including technical assistance, regional training programmes, and platforms for experience exchange.
By ATAF Communication April 15, 2025
A key outcome of the training was the heightened awareness among FIRS officials of the critical role data plays in modern tax administration. 
By ATAF Communication April 12, 2025
The training aimed to strengthen the capacity of tax officials to detect, investigate, and prosecute financial crimes such as tax evasion, money laundering, and illicit financial flows. It focused on practical approaches to financial crime investigation within the tax context.
By ATAF Communication April 8, 2025
Mr. Logan Wort emphasized the critical role of taxpayers in fostering economic growth and sustaining public services.
By ATAF Communication April 7, 2025
Taxation is a key aspect to increase gender equality since tax is one of the building blocks of society. In particular, it creates domestic resources which are a major source of funding for economic development and empowerment.
By ATAF Communication March 20, 2025
ATAF emphasised the importance of harmonised tax systems and advocating for revenue-generation mechanisms that would sustain government finances while fostering trade liberalisation. 
By ATAF Communication February 27, 2025
ATAF is gearing up for a highly anticipated event: the ATAF Women in Tax Network Leadership Conference. Set to take place in Cape Town, South Africa, on March 5-6, 2025, this conference promises to be a pivotal moment for women in the tax and economic sectors across Africa.
By ATAF Communication February 25, 2025
The ATAF Women In Tax Network (AWITN) pledge is a commitment by various countries to adopt a focused, gender-sensitive approach to tax policy and administration.
By ATAF Communication February 20, 2025
The workshop aimed to bridge the gap between tax authorities and the media, improving the clarity and accessibility of tax-related information to foster public awareness and boost tax compliance.
Show More