Tax Essentials: Country by Country Reporting

Introduction of Country by Country Reporting (CbCR) requirements to Zambia in 2021 marked the final step in the implementation of the Organisation for Economic Cooperation and Development (OECD)  three-tiered approach to transfer pricing documentation. This reporting obligation may apply to you, over and above the standard transfer pricing documentation requirements. Attached is our “BDO Tax Essentials” with information pertaining to the CbCR regime and how it may affect your reporting obligations. We have also summarised the filing and notification protocol into a decision tree to further assist you in determining your status.

The Key points are as follows:

• CbCR regulations apply in Zambia as of 1 January 2021.
• The reporting threshold is K4.795 billion consolidated revenue of the Multinational Enterprise (MNE) in the immediately preceding year.
  • Which currently converts to approximately EUR267 million, USD282 million and GBP229 million
• Constituent entities are required to notify ZRA of the Ultimate Parent Entity/Surrogate Parent Entity no later than the last day of the reporting accounting year
• There are NO competent authority agreements in place with the Zambian Revenue Authority therefore ALL resident constituent entities of qualifying MNE’s are required to notify the ZRA and file the CbCR no later than 12 months after the last day of the reporting accounting year of the MNE.