ZAMBIA Trends and Developments
Key Tax Legislative Changes in Zambia: Implications of the 2025 Supplementary and 2026 National Budgets Introduction In 2025, the Minister of Finance of the Republic of Zambia introduced a series of significant tax policy changes. The first wave of amendments was deliv - ered through the 2025 Supplementary Budget, fol - lowed by additional measures presented in the 2026 National Budget on 27 September 2025. Together, these reforms mark a continued effort to modernise the tax framework, enhance revenue mobilisation, and streamline compliance. Among the key changes are: • the reform of the betting tax regime; • the introduction of a Minimum Alternative Tax (MAT); • an increase in withholding tax on government securities; • the elimination of penalties on voluntary disclo - sures; • the extension of property transfer tax (PTT) relief for qualifying group reorganisations; and • value added tax debt remission. Collectively, these reforms signal a strategic shift toward a more robust and investor‑aligned tax envi - ronment, while promoting compliance and broadening the tax base. The Betting Tax Regime Historically, the tax regime governing betting activities comprised a 25% presumptive tax on gross takings (Net Gaming Revenue, NGR) and a 15% withhold - ing tax on customer winnings. Online gaming opera - tors faced an even higher effective burden, with 35% of NGR payable in taxes. This landscape shifted on 8 August 2025 following the assent of the Customs and Excise Amendment Act, which introduced a 10% excise duty on betting services in addition to the exist - ing presumptive and withholding tax obligations. The excise duty functions as an indirect tax imposed on specified betting‑related transactions or revenues, as set out in the Act. With the amendment in force, betting activities became subject to the newly enacted 10% excise duty, transitioning the measure from a policy proposal
to a binding statutory requirement. Operators within the betting industry were required to account for, col - lect, and remit the excise duty, with payments due by the 15th day of the month following the transaction period. Failure to comply exposed stakeholders to penalties and interest under the customs and excise regime. The excise duty on betting services was subsequent - ly suspended through Statutory Instrument No 1 of 2026. Consequently, excise duty is no longer charged on betting activities. In its place, the government of Zambia introduced a betting levy, which effectively replaces the suspended excise duty framework. Introduction of the betting levy As the tax regime currently stands in Zambia’s bet - ting and gaming sector, recent legislative amend - ments have fundamentally restructured the manner in which betting and gaming activities are taxed. The Income Tax (Amendment) Act No 17 of 2025 amended the Ninth Schedule to the Income Tax Act so as to remove presumptive taxes previously applicable to online betting and gaming activities, thereby confining that Schedule to brick-and-mortar betting and gaming operations. Following these amendments, parliament enacted the Betting Levy Act No 27 of 2025, which introduced a distinct statutory levy applicable to all online bet - ting and gaming activities. This Act implements a 5% levy on customer deposits and a 5% tax on customer withdrawals. The levy is structured as a transaction- based impost rather than a tax on profits or net gam - ing revenue, reflecting the government’s intention to capture revenue at the point of cash movement within betting platforms. Under this Act, a 5% levy applies to all deposits made into customer gaming accounts and an additional 5% levy applies to all withdrawals from these accounts. The effect of these reforms is that income-based taxa - tion under the Income Tax Act now primarily governs land-based betting operations, while online betting and gaming activities are principally subject to taxa - tion through the Betting Levy Act.
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