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Zambia: Transfer pricing measures included in 2020 budget

Zambia: Transfer pricing measures in 2020 budget

The Minister of Finance in late September 2019 presented the 2020 budget.


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Among the tax measures included in the 2020 budget are transfer pricing amendments that would:

  • Provide for price premium adjustments
  • Authorize the tax administration to request sales agreements and third-party invoices relating to the sale of minerals
  • Extend the use of the “reference pricing” to adjust the pricing of purchases between related or associated persons
  • Treat or deem the agreed sale price between a resident or non-resident person with an unrelated person to be the “reference sales price” for tax purposes of the Zambian person when the agreed price is greater than the reference price and the sale to the unrelated person of a base or precious metal does not involve further milling, blending, treatment, refinement or transformation

Other transfer pricing-related proposals in the budget would revise the definition of certain terms—actual conditions, arm’s length conditions, and related or associated persons—and would provide for a transfer pricing adjustment arising from a transaction with a resident (domestic) and non-resident related person

Read a September 2019 report [PDF 1 MB] prepared by the KPMG member firm in Zambia

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