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We provide a wealth of publications by PwC Zambia providing informed commentary on current developments in the tax arena, both locally and internationally.
Through analysis and comment on new law and judicial decisions of interest, they assist business executives to identify developments and trends in tax law and revenue practice that might impact their business.
In this alert:
Zambia’s Voluntary Disclosure Programme: A proactive approach to managing legacy tax exposure
Zambia has introduced a permanent Voluntary Disclosure Programme (VDP) under the Income Tax Act, effective 1 January 2026. The programme allows taxpayers to voluntarily disclose omissions, errors, or mistakes in their tax affairs in exchange for a complete waiver of penalties and the possible remission of interest. It covers all taxes assessed under the Income Tax Act, including Corporate Income Tax (CIT), Withholding Tax (WHT), Pay-As-YouEarn (PAYE), and transfer pricing. The Zambia Revenue Authority (ZRA) has also signalled a willingness to extend favourable treatment to Value Added Tax (VAT) and Customs matters under its discretionary powers.
While the VDP is permanent, its relevance is driven by timing. Once ZRA commences an audit or enquiry, access to relief may be lost for issues within scope.
Transfer pricing is often the most effective starting point for a voluntary disclosure conversation because it is where cross-border positions and documentation requirements are typically tested first, and where a focused review can quickly surface related exposures across other tax types. In practice, we are also seeing transfer pricing enquiries used as a gateway into broader cross-border matters. A targeted review at the outset helps organisations understand where the real issues sit and decide next steps with greater clarity and control.
We would welcome the opportunity to discuss your tax affairs confidentially and explore how PwC can assist you with a tax health check and, where appropriate, a VDP application.
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