ZAMBIA Law and Practice Contributed by: Mulenga Chiteba, Constance Namatai Mwango and Bwalya Milunga, Mulenga Mundashi Legal Practitioners
15. Foreign Payment Restrictions 15.1 Restrictions on Outbound Payments Relating to Uncontrolled Transactions Zambia’s Transfer Pricing Rules do not restrict outbound payments relating to uncontrolled transactions.
15.3 Effects of Other Countries’ Legal Restrictions The Transfer Pricing Rules do not provide for rules regarding the effects of other countries’ legal restrictions. 16. Transparency and Confidentiality 16.1 Publication of Information on APAs or Transfer Pricing Audit Outcomes The ZRA does not publish information on APAs or transfer pricing audit outcomes. 16.2 Use of “Secret Comparables” The Transfer Pricing Rules do not prohibit the use of secret comparables. In fact, the ZRA has procured a database for the use of comparables.
15.2 Restrictions on Outbound Payments Relating to Controlled Transactions
Zambia’s Transfer Pricing Rules do not restrict outbound payments relating to controlled trans - actions.
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