Data points
- Annual turnover below which a purely local group owes no documentation[1]
- K50m
- To produce the files after a written request from the Zambia Revenue Authority[2]
- 30 days
- Consolidated group revenue that triggers country-by-country reporting[4]
- K4.795bn
- After year end to file the country-by-country report[3]
- 12 months
- Penalty for failing to keep documentation, about ZMW 32 million[2]
- 80m units
- When Zambia's first OECD transfer pricing country profile was published[5]
- Oct 22, 2025
Zambia keeps its transfer pricing files on the shelf. Nothing goes to the Zambia Revenue Authority (ZRA) with the return. The ZRA asks in writing, and from that point you have a month to hand the files over.
The four facts to know:
- Every Zambian entity inside a multinational group keeps a master file and a local file, whatever its turnover.
- A purely Zambian group escapes the documentation duty only below K50 million of annual turnover. The arm's length rules still bind it.
- Both files must be ready by the income tax return due date and produced within 30 days of a written ZRA request.
- Failing to keep them costs 80 million penalty units, about ZMW 32 million.
What are Zambia's master file and local file requirements in 2026?
A master file, a local file and, for large groups, a country-by-country report. All three are prepared annually and kept, not filed. The turnover exemption is the piece most readers get wrong: it protects a local business, never a multinational group's Zambian entity.
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| Fact | Position in 2026 | Source |
|---|---|---|
| Master file and local file | Both required for an entity inside a multinational group | OECD |
| Documentation exemption | Local groups below K50 million of annual turnover only | Zambia Revenue Authority |
| Filed or kept | Kept, produced within 30 days of a written ZRA request | OECD |
| Country-by-country reporting | Consolidated group revenue above K4.795 billion | Zambia Revenue Authority |
| Headline penalty | 80 million penalty units, about ZMW 32 million | OECD |
The ZRA sets out its own position in the practice note it published in 2021[1], which is the primary source for the turnover threshold used throughout this page.
Who must prepare transfer pricing documentation in Zambia?
Any Zambian entity that belongs to a multinational group, with no turnover carve-out at all. A purely Zambian business is exempt from the documentation duty only where annual turnover is below K50 million in the charge year. That line rose from K20 million for charge years from 31 December 2021. The trigger is turnover, not the value of the related-party transactions.
The arm's length rule itself has no threshold. It binds every transaction between associated persons whatever the turnover, and the ZRA says so in terms: the K50 million line does not apply to a multinational enterprise, and all the transfer pricing rules still apply to all transactions between associated persons irrespective of annual turnover. Only the documentation duty moves with the number. The regulations do not say what ownership percentage makes two persons associated.
Does Zambia require a master file?
Yes. Zambia's own OECD transfer pricing country profile[2], published in October 2025, confirms that the domestic framework requires a master file, a local file and a country-by-country report, each built to the matching OECD annex.
The confirmation matters because the ZRA's own practice notes never use the phrase "master file". Zambia adopted the three-tier model through statutory instruments in 2020 and 2021 rather than by naming the OECD documents, which is why the label was ambiguous until the country profile landed. If you were told Zambia has no master file requirement, that advice predates October 2025.
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What must the Zambia local file contain?
Entity-level evidence for each category of related-party transaction: what the transaction was, which transfer pricing method you applied to it, and the comparables that support the arm's length price. It is prepared annually, kept in place, and produced to the Commissioner-General on request rather than attached to the return. The master file holds the group-level material alongside it.
We structure local files by transaction type, following the OECD order: organisation chart and business strategy, then the functional analysis, then an economic analysis for each transaction category. For the background, see our guides to transfer pricing documentation and to building a defensible intercompany agreement.
What are Zambia's country-by-country reporting rules?
A country-by-country report is due where a group's consolidated revenue exceeds K4.795 billion in the preceding accounting year. Since 1 January 2023 that single kwacha figure has replaced the old dual test of EUR 750 million or K4.795 billion. A Zambian constituent entity notifies the Commissioner-General by the last day of the reporting accounting year, and the report itself follows within 12 months.
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| Obligation | Threshold or scope | Deadline | Source |
|---|---|---|---|
| Country-by-country report | Consolidated group revenue above K4.795 billion, a single kwacha threshold since 1 January 2023 | Within 12 months of year end | Zambia Revenue Authority |
| Country-by-country notification | Any Zambian constituent entity of a qualifying group | Last day of the reporting accounting year | Zambia Revenue Authority |
The report buys you nothing in an audit. The ZRA is barred from using it as the basis for a transfer pricing adjustment, so it supports risk assessment and nothing more. The detail is in the ZRA practice note on country-by-country reporting[3], and the kwacha threshold in the 2023 practice notes[4].
Does Zambia require a transfer pricing form with the return?
No. The sourced guidance attaches no standalone transfer pricing form or schedule to the income tax return. The master file and the local file are kept and produced on request. Whether a disclosure box appears on a future version of the return is not confirmed against current ZRA return guidance, so check the form you are filing rather than assuming it is clean.
When is Zambia transfer pricing documentation due?
Ready by the income tax return due date, then handed over within 30 days of a written request from the Commissioner-General. The country-by-country notification falls on the last day of the reporting accounting year, and the report within 12 months of year end.
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| Obligation | Deadline | Source |
|---|---|---|
| Master file and local file ready | By the income tax return due date | OECD |
| Production to the ZRA on written request | Within 30 days | OECD |
| Country-by-country notification | Last day of the reporting accounting year | Zambia Revenue Authority |
| Country-by-country report | Within 12 months after year end | Zambia Revenue Authority |
| Corporate return, 31 December year end | 21 June of the following year, not confirmed for 2026 | Not confirmed |
| Retention period | Not confirmed. Secondary sources report 10 years | Not confirmed |
What language and currency does Zambia require?
English, which is Zambia's official language. A record in any other language has to be translated into English by a Notary Public, at the taxpayer's own cost, before it is produced to the Commissioner-General. The reporting currency is the Zambian kwacha. Any conversion rule for foreign-currency records is not confirmed against a primary source.
What are the penalties for missing transfer pricing documentation in Zambia?
Failing to keep transfer pricing documentation carries 80 million penalty units, about ZMW 32 million at the current penalty-unit value of ZMW 0.40. A separate charge applies to producing the files late. The two sources state the kwacha equivalent differently because the penalty-unit value itself has changed since 2019, so both figures appear below rather than one that looks tidier.
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| Failure | Penalty | Kwacha value | Source |
|---|---|---|---|
| Failing to prepare and keep transfer pricing documentation | 80 million penalty units | About ZMW 32 million, at a penalty unit of ZMW 0.40 | OECD |
| Failing to produce documentation within 30 days of a written request | 80,000,000 penalty units | K24,000,000, effective 1 January 2019 | Zambia Revenue Authority |
| Penalty charged as a percentage of the adjustment | Not confirmed | Not confirmed | Not confirmed |
What is the parent company exposed to?
An undocumented Zambian subsidiary exposes the parent to an adjustment at the ZRA's discretion, a penalty-unit fine, and economic double taxation when the same profit is taxed in two countries. The ZRA can rebuild related-party pricing to the arm's length result on its own analysis. A country-by-country report is no shield, because it cannot be used as the basis for an adjustment in the first place.
The exposure runs past pricing into substance. Where a Zambian entity carries little real activity behind the intercompany charges it books, the arm's length review and the question of what the entity actually does arrive together. Documentation prepared before the ZRA asks is the parent's only real defence.
How does Zambia differ from the OECD baseline?
Zambia is an Inclusive Framework member and not an OECD member, so the three-tier model arrives through domestic statutory instruments rather than through membership. Three practical differences follow: the documentation exemption turns on turnover rather than on the value of related-party transactions, the country-by-country threshold is set in kwacha rather than in euro, and an advance pricing agreement programme is not confirmed from any primary source.
Zambia received its first OECD transfer pricing country profile in the third batch published on 22 October 2025[5]. That is the document that settled the master file question and confirmed both the English-language rule and the 30-day production window. The statutory instruments behind the regime are published on the Zambia Legal Information Institute[6].
How we help with Zambia transfer pricing
Zambia gives you 30 days from a written request, which is not enough time to build a local file from nothing. We prepare and maintain the master file, the local file and the country-by-country notification across every jurisdiction a group sits in, so the Zambian files are finished before the ZRA asks for them. See how our transfer pricing software works.
Book a demo to get a documentation gap assessment for your Zambian entity.
Official sources
6 sources
- 1.Zambia Revenue Authority. Practice Note No. 1 of 2021 (transfer pricing documentation threshold)
- 2.OECD. Transfer pricing country profile: Zambia (October 2025)
- 3.Zambia Revenue Authority. Practice Note No. 2 of 2022 on Country-by-Country Reporting
- 4.Zambia Revenue Authority. Practice Notes 2023 (single kwacha country-by-country threshold)
- 5.OECD. Third batch of updated transfer pricing country profiles, 22 October 2025
- 6.Zambia Legal Information Institute. Statutory Instrument No. 117 of 2020 (transfer pricing regulations)
Article by
Sam Suechting
Head of Product, Commenda
Sam is a seasoned expert in sales tax, leading Commenda's effort to build the worlds most comprehensive database of global tax rules and business regulations. At Silverhaze Partners, he worked in early-stage venture capital, where he saw firsthand how tax complexity and regulatory friction hold back startups from scaling internationally. That experience now powers his work at Commenda-bringing clarity, precision, and real-world insight to one of the most frustrating parts of doing business globally.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
