Country-by-Country Reporting – Compilation of 2024 Peer Review Reports

First reporting fiscal year: Ending on 31 December 2021

Consolidated group revenue threshold: EUR 750 million (ZMW 4.795 billion for Zambian resident MNE Groups)

Filing deadline: 12 months following the end of the reporting fiscal year

Local filing required: Yes

Surrogate parent entity filing permitted: Yes

First review of domestic legal framework: 2021/2022

Zambia’s 2021/2022 peer review included a recommendation that Zambia amend the definition of MNE Group or otherwise clarify the definition to be in line with the standard. Zambia has amended the definition and this recommendation is therefore removed.

Zambia’s 2021/2022 peer review included a recommendation that Zambia amend the definition of Ultimate Parent Entity or otherwise clarify the definition to be in line with the standard. Zambia has amended the definition and this recommendation is therefore removed.

Zambia’s 2021/2022 peer review included a recommendation that Zambia amend the definition of MNE groups to specify that it does include excluded MNE groups, or to otherwise specify a threshold requirement for local filing. Zambia has amended the definition and this recommendation is therefore removed.

Zambia’s 2021/2022 peer review included a recommendation that Zambia amend the definition of surrogate filing or otherwise clarify the definition to be in line with the standard. Zambia has amended the definition and this recommendation is therefore removed.

Zambia has a legislative requirement for local filing which is in line with the standard but which is in effect despite Zambia not yet meeting all of the consistency, confidentiality and appropriate use conditions. It is therefore recommended that Zambia take steps to ensure that local filing only occurs in the circumstances permitted under the minimum standard. This recommendation remains in place since the 2021/2022 peer review.

It is recommended that Zambia clarify that the annual consolidated group revenue threshold calculation rule applies in line with the OECD guidance on currency fluctuations in respect of an MNE Group whose Ultimate Parent Entity is located in a jurisdiction other than Zambia. This recommendation remains in place since the 2021/2022 peer review.

It is recommended that Zambia publish the full content and format requirements of the CbC Report. This recommendation remains in place since the 2021/2022 peer review.

Zambia has no bilateral relationships in place for the exchange of CbC reports nor processes to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework.

It is recommended that Zambia take steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions and with which Zambia has an international exchange of information agreement in effect that allows for the automatic exchange of tax information. This recommendation remains in place since the 2018/2019 peer review.

It is recommended that Zambia take steps to implement the necessary processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework. This recommendation remains in place since the 2018/2019 peer review.

Zambia does not yet have controls in place to ensure the appropriate use of CbC reports.

It is recommended that Zambia take steps to ensure that the appropriate use condition is met ahead of the first exchanges of information. This recommendation remains in place since the 2018/2019 peer review.