As countries around the world assess the implications of new international tax reforms, one question continues to emerge: how will these changes affect revenue collection, taxpayer compliance, and the administration of tax systems?
In Zambia, this question is taking centre stage as the country evaluates the potential implications of OECD Pillar One – Amount B, a new framework designed to simplify and standardise the application of the arm’s length principle to baseline marketing and distribution activities.
From 4–8 May 2026, the Zambia Revenue Authority (ZRA), with support from ATAF, conducted an assessment to better understand the implications of implementing Amount B for Zambia’s tax system.
The assessment examined several key areas, including the potential impact on corporate income tax revenue, transfer pricing compliance, administrative efficiency, and taxpayer burden. It also sought to identify multinational enterprises that could fall within the scope of the new rules and evaluate Zambia’s legal, administrative, and institutional readiness to implement them.
Led by ATAF’s Dr Ezera Madzivanyika and Ms Mercy Mbithi, the exercise combined technical analysis with extensive stakeholder consultations. Officials from the Ministry of Finance, the Zambia Revenue Authority, tax advisory firms, and audit firms contributed perspectives on the opportunities and challenges that Amount B could present in practice.
Data analysis formed an important component of the assessment, helping to identify potentially affected multinational enterprises and providing insights into the possible revenue implications of the new framework.
Recognising that effective implementation requires a strong understanding of the rules, the engagement also included a capacity-building programme for officials from the Zambia Revenue Authority and the Ministry of Finance. The sessions provided participants with a detailed overview of the design and application of Amount B, helping to strengthen readiness for future policy considerations.
Stakeholders who participated in the consultations welcomed the initiative and highlighted the importance of continued dialogue on emerging international tax developments. As countries navigate an increasingly complex global tax environment, such engagements provide valuable opportunities to build technical expertise, assess policy options, and ensure that international tax reforms are implemented in ways that reflect national priorities and circumstances.
