ZAMBIA Trends and Developments Contributed by: Mulenga Chiteba and Constance Namatai Mwango, Mulenga Mundashi Legal Practitioners
Use of country-by-country reports The Commissioner-General shall maintain con - fidentiality of the information in accordance with the data protection laws in Zambia. The Com - missioner-General may only use such informa - tion for: • assessing high level transfer pricing risks and other BEPS-related risks; • assessing the risk of non-compliance by members of the multinational enterprise group with applicable transfer pricing rules; and • economic and statistical analysis.
• revenue; • profit or loss before income tax; • income tax paid; • income tax accrued; • stated capital; • accumulated earnings; • number of employees; and • tangible assets other than cash or cash equivalents. The country-by-country report shall also include an identification of each constituent entity of the multinational enterprise group setting out the state of tax residence of the constituent entity, and, where different from the state of tax resi - dence, the state under the laws of which the constituent entity is organised, and the nature of the main business activity or activities of the constituent entity.
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