ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia

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ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
ZAMBIA NATIONAL
BUDGET 2021
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
TABLE OF CONTENTS

1.0 BUDGET OVERVIEW 					 1

2.0 BUDGET HIGHLIGHTS FOR 2021 		   4

3.0 DIRECT TAXES 						 5

4.0 VALUE ADDED TAX 					 7

50. PROPERTY TRANSFER TAX			        8

6.0 TOURISM 							 9

7.0 CUSTOMS AND EXCISE              10

8.0 TRANSFER PRICING                12

9.0 NON-TAX MEASURES                12

10.0 DOUBLE TAXATION TREATIES       13

11.0 ABOUT US 		                    14

   BDO ZAMBIA - Budget 2021
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
“Stimulating
                                                   economic recovery &
                                                   building resilience...

         1.0 BUDGET OVERVIEW
T  he September 2020 Zambia Budget
   Address for the year 1 January 2021 to 31
December 2021 was delivered to the National
                                                 to favour predictability in policy formulation
                                                 owing to the lack of drastic tax policy measures
                                                 and proposals, as has been the case in budgets
Assembly on Friday 25 September, 2020 by         in the recent past. The central macro-economic
the Honourable Dr. Bwalya K.E. Ng’andu, MP,      objectives of the 2021 budget outlined by the
Minister of Finance.                             Minister are as follows:
                                                 a) Achieve a real GDP growth rate of 1.8%, as
The Minister presented a K119 billion budget     opposed to 3% proposed in last year’s budget;
with the theme “Stimulating Economic             b) Reduce the inflation rate towards the 6% -
Recovery and Building                                                 8% range, maintaining
Resilience to Safeguard                                               the target proposed in last
Livelihoods and Protect the                                           year’s budget;
Vulnerable”. At a glance,                                             c) Reduce the fiscal deficit
the 2021 budget appears to                                            to 9.3% as opposed to
largely be a continuation                                             5.5% set in last year’s
of the 2020 budget                                                    budget; and
agenda with a central                                                 d) Achieve domestic
purpose of stimulating                                                revenue collection of not
economic growth. The                                                  less than 18% of GDP as
uniformity between the                                                opposed to 22% proposed
two budgets can even be                                               in last year’s budget.
inferred from the similarity
in the themes, as last year’s budget theme       As a backdrop to the 2021 budget, the Minister
was “Focusing national priorities towards        revealed that real GDP growth is projected
stimulating the domestic economy”. It is clear   at negative 4.2% in 2020, representing the
that the Minister’s central objective remains    first recession in the country since 1998.
stimulating growth in the Zambian economy        Overall, all sectors of the Zambian economy
and to this end, he unveiled a medium-term       are expected to record negative growth due
Economic Recovery Program (“ERP”), which         to passive economic activity as a result of
is the successor to the Economic Stabilization   COVID-19 suppression measures as well as
and Growth Program (“ESGP”) which ended in       country-wide electricity rations. The Minister
2019.                                            however expects the telecommunications and
                                                 agricultural sectors to register positive growth.
The ERP aims to bolster economic growth          Continued depreciation of the Kwacha may
and restore debt sustainability and appears      potentially curtail the anticipated growth.

                                                        BDO ZAMBIA - Budget 2021              1
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
“  ...to safeguard
                                                           livelihoods and
                                                           protect the
                                                           vulnerable

The Minister also notes that the external           Imports of goods by Zambians declined by
public debt stock in 2019 increased to USD          30% to USD 2.3 billion from USD 3.3 billion
11.97 billion, representing a 4.3% increase         in 2019. Similarly, export earnings declined
from 2019. He notes that Government, with           by 15.5% from USD 3.8 billion to 3.2 USD
the help of various legal and financial advisors,   billion. A decline in economic activity as result
is in the process of developing a liability         of COVID-19 suppression measures as well as
management strategy aimed at achieving debt         the deprecation of the Kwacha significantly
sustainability.                                     contributed to the drop in imports and
                                                    export earnings. Copper earnings in particular
The Zambian Kwacha depreciated against the          declined by 14.8%, however, copper export
US Dollar to K19.95 as at 22 September 2020,        volumes increased by 16.5% to 449,000
representing a 41.9% drop from comparatives         metric tones.
as at end of December 2019. Furthermore,
inflation exceeded the medium-term target           In the 2021 budget, debt servicing constitutes
of 6% - 8% to hit 15.5% as at end of August         the largest expenditure, representing around
2020.                                               40% of the total budget and further adding
                                                    pressure on the fiscus. The table on the
                                                    following page outlines the expenditure by
      Inflation exceeded                            functions of Government proposed in the 2021
                                                    budget and provides a 2020 comparative.
      the medium-term
                                                    Some of the notable achievements included
     target of 6% - 8% to                           in this budget are the amendment of the
                                                    Republican Constitution; expansion in our
           hit 15.5%                                health and education facilities; enhanced
                                                    interconnectivity of our country through
                                                    improved road infrastructure; and the
                                                    provision of social safety nets for the
                                                    vulnerable.

 2        BDO ZAMBIA - Budget 2021
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
“   Debt servicing
constitutes 40% of
the total budget
    1.0 BUDGET OVERVIEW

                                                                         Share                       Share
                         Function                         2021             of          2020            of
                                                                        budget                      budget
     General Public Services                         57,819,227,707     48.3%    K44,080,742,270    41.6%
          Domestic Debt Interest                       18,338,481,000              12,634,848,146
          External Debt Interest                       27,745,178,541              21,090,794,856
          Dismantling of Arrears                       2,762,080,579                2,278,733,732
          Local Government Equalization Fund           1,164,567,612                1,164,567,612
          General Elections and Voter Registration      598,112,678                 135,000,000
          Constituency Development Fund                 249,600,000                 249,600,000
          MP's Gratuity                                 202,073,000
          Public Affairs and Summit Meetings            200,000,000                 143,726,597
          Contingency                                   125,000,000                 100,636,628
          Compensation Fund                             100,000,000                 100,000,000
          Sinking fund                                       -                      636,000,000

     Defence                                          5,642,820,724     4.7%     6,526,391,423      6.2%
     Public Order and Safety                          3,078,694,172     2.6%     4,042,702,155      3.8%
     Economic Affairs                                21,499,987,741     18%      21,833,351,543     20.6%
          •     Road infrastructure                    6,214,145,268               10,552,606,147

          •     Farmer Input Support Programme         5,701,404,933                1,111,840,201

          •     International Airports                  567,334,377                 1,823,481,818

          •     Strategic Food Reserves                 517,500,000                 660,000,000

          •     Rural Electrification Fund              307,199,557                 166,339,781

          •     Empowerment Funds                       266,285,212                       -
          •       O/w You Empowerment Funds             155,237,025                       -
          •     Energy/Power Infrastructure                                        11,167,970,334

     Environment Protection                           955,530,142       0.8%       611,777,853      0.6%
     Housing and Community Amenities                  2,221,524,168     1.9%      3,460,376,555     3.3%
          •     Water Supply and Sanitation            2,172,274,286                2,620,137,161

          •     Markets, Bus Stations and Solid                                      24,441,200
                Waste Management
     Health                                           9,653,313,513     8.1%      9,336,591,584
          •     Infrastructure                         1,731,846,564                1,479,947,346

          •     Drugs and Medical Supplies             1,392,443,990                900,622,880

          •     Operations for Hospitals                627,263,831                 686,266,173

     Recreation, Culture and Religion                 151,357,265                  383,045,401
     Education                                       13,772,752,981               13,121,648,466
          •     Infrastructure                         1,216,937,500                1,071,920,363

          •     Skills Development Fund                 178,857,469                 179,181,956

     Social Protection                                4,820,803,202               2,580,984,987
          •     Social Cash Transfer                   2,344,175,162                1,047,422,180

          •     Public Service Pension Fund            1,067,955,725                1,020,387,712

          •     Food Security Pack                     1,100,000,000                122,162,992

     TOTAL                                           119,616,011,615    100%     106,007,612,236

                                                                        BDO ZAMBIA - Budget 2021                      3
    Some of the notable achievements included in this budget are the amendment of the Republican Constitution; expansion in our health
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
“  New tax
       allowance for use
       of selected local
       raw materials

          2.0 BUDGET HIGHLIGHTS FOR 2021
2.1 DIRECT TAXES
• PAYE threshold and bands have been increased
• Development allowance in horticulture increased to 5 years from 3 years
• Tax rate on betting increased to 25% from 10%
• Income tax rate on hotels and lodges reduced to 15% from 35%
• Introduction of new tax allowance for the use of selected local raw materials

2.2 VALUE ADDED TAX
• All tractors zero rated
• Full body sanitisation equipment zero rated

2.3 CUSTOMS AND EXCISE
• Import duty on safari game viewing motor vehicles suspended
• licences paid by tourism enterprises and hotel managers suspended
• Import duties on items used to support horticulture and floriculture subsectors removed or
   suspended
• Export duty on crocodile skin removed
• Import duty on copper ores and concentrates removed
• High-value second hand motor vehicles to be subjected to ad valorem import duty
• Import duty increased to 40% on various agro-processed products
• Excise duty on plastic flat bags introduced at 30%
• Import duty on electric motor vehicles reduced to 15% from 30%

        PAYE                                            All
      threshold
                                                     tractors
         and
                                                       zero
        bands
      increased                                       rated

  4       BDO ZAMBIA - Budget 2021
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
THE BUDGET IN DETAIL

          3.0 DIRECT TAXES
All of the following measures will take       3.3 INCREASE OF TAX CREDIT FOR
effect from 1st January, 2021.                    DIFFERENTLY ABLED PERSONS
                                              The tax credit for differently abled persons
3.1 PERSONAL TAX RATES                        has been increased to K500 per month
                                              from the current K250 per month.
The exempt threshold for Pay-As-You-Earn
has been increased to K4,000 from K3,300      3.4 INCREASE IN DEVELOPMENT
per month and the bands have been                 ALLOWANCE CLAIM PERIOD
adjusted as follows:                          The number of years for claiming the 10%
                                              development allowance in the horticulture
                                              and floriculture subsectors has been
 Income Bands       Income          Tax
                                              increased to 5 years from the existing 3
   Per Annum         Bands         Rate %
                                              years. This allowance applies to persons
                   Per Month                  growing rose flowers, tea, coffee, banana
                                              plants or citrus fruit trees or other similar
  First K48,000    First K4,000           0   plants or trees.

  Next K9,600       Next K800         25

  Next K25,200     Next K2,100        30

  Balance over     Balance over      37.5
    K82,800          K6,900

3.2 INCREASE THE INCOME TAX                     Development allowance
    DEDUCTION AVAILABLE FOR
    EMPLOYING DIFFERENTLY ABLED
                                                in horticulture increased
    PERSONS                                      to 5 years from 3 years
The amount allowable for deduction by
an employer for employing a differently       3.5 INCREASE IN INCOME TAX RATE IN
abled person has been increased to K2,000         THE GAMING AND BETTING
per annum from K1,000 per annum. This is          INDUSTRY
aimed at encouraging the employment of        The tax rate on betting has been increased
differently abled persons.                    to 25% from 10% of gross takings.

                                                     BDO ZAMBIA - Budget 2021           5
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
“  Tax rate on
      betting increased
       to 25% of gross
           takings

3.6 REDUCTION OF INCOME TAX                      3.9 CURRENCY FOR KEEPING BOOKS
     RATES FOR HOTELS AND LODGES                     OF ACCOUNT
The corporate income tax rate on                 It will be mandatory to keep books of
income earned by hotels and lodges on            account in Kwacha. Mining companies with
accommodation and food services has              at least 75% of their earnings in foreign
been reduced to 15% from 35%. This is            currency from abroad or within Zambia
aimed at resuscitating the tourism sector        may keep accounts in US Dollars.
and promoting local tourism following the
disruptions caused to the industry by the        3.10 INCREASE IN COMMISSIONS TO
COVID-19 pandemic.                                 TAX AGENTS
                                                 The maximum commission payable to tax
3.7 NEW LOCAL CONTENT                            agents will be increased from 3% to 10% in
     ALLOWANCE                                   order to allow agents to effectively recover
A local content allowance for income             costs for their operations.
tax purposes at the rate of 2% will be
introduced for businesses using selected         3.11 INTRODUCTION OF WHT ON
local raw materials. This is aimed at                 ROYALTY FINANCING
encouraging the use of locally available         The amendment introduces withholding
raw materials such as mangoes, pineapples        tax on payments made under royalty
and cassava.                                     financing agreements by a Zambian
                                                 resident to a non-resident.
3.8 ZAMBIA DEVELOPMENT AGENCY
      TAX INCENTIVES                             3.12 TAX APPLICABLE ON EMPLOYEE
The investment threshold for a Zambian                 LOAN BENEFITS
citizen to qualify for tax incentives under      The amendment provides for the interest
the Zambia Development Agency Act No.            rate to be used in determining the
11 of 2006 will be reduced to $100,000           benefits tax payable by employers on
from $500,000 for those intending to             loans advanced to employees. This will
operate in a priority sector, a multi facility   be amended from an ‘open market rate’
economic zone or industrial park.                system to a rate of 2% above the Bank of
                                                 Zambia Policy Rate.
3.8 CLARIFICATION OF THE LIMITATION
     RULE ON INTEREST DEDUCTIBILITY              3.13 UPDATED STATUTORY BODY
The amendment seeks to clarify that the                MANDATES
limitation rule on interest deductibility        Statutory bodies to request for Taxpayer
introduced in 2019 applies on all interest       Identification Numbers and Tax Clearance
deductions of borrowings of both revenue         Certificates before registering and
and capital nature.                              renewing membership or issuing any
                                                 licenses and permits.
  6       BDO ZAMBIA - Budget 2021
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
“ Full body
                                                 sanitisation
                                                 equipment zero
                                                 rated
         4.0 VALUE ADDED TAX
All of the following amendments to the        ZRA to provide clarity on when the two-
VAT Act will take effect from 1st January,    year limitation period is to commence.
2021 except where otherwise stated.
                                              4.7 DEFINITION OF “PLACE OF SUPPLY
4.1 RATE OF VAT                                    OF GOODS”
The VAT rate remains unchanged at 16%.        ZRA to provide clarity on the definition of
                                              “Place of supply of goods”.
4.2 ZERO RATING OF TRACTORS USED
      IN AGRICULTURE INDUSTRY                 4.8 ESCALATORY FINE TO BE
All tractors used in agriculture to be zero       CHARGEABLE ON FALSE RETURNS
rated for VAT purposes.                           AND STATEMENTS
                                              The applicable penalties are as follows:
4.3 EQUIPMENT USED IN FULL BODY
     SANITISATION TO BE ZERO RATED
                                                  OFFENCE            APPLICABLE PENALTY
As a result of the COVID-19 pandemic, all
equipment used for full body sanitisation
will be zero-rates for a period of one year    First occurrence   Up to 60,000 penalty
effective 26 September 2020.                                      units (K18,000) per period
                                                                  audited.
4.4 TAXABLE SUPPLIER OBLIGATED TO
     PROVIDE AN ELECTRONIC                     Second             Up to 120,000 penalty
     PAYMENT MACHINE                           occurrence         units (K36,000) per period
Taxable suppliers are obliged to provide an                       audited.
electronic payment machine and failure to
comply attracts a penalty.
                                               Third occurrence   Up to 240,000 penalty
4.5 FINE CHARGEABLE FOR EVASION                                   units (K72,000) per period
     OF VAT                                                       audited.
The fine chargeable for evasion of VAT has
been Increased to 300,000 penalty units        Any repeat event   Deemed as evasion of tax
(K90,000) from 30,000 penalty units            beyond third       and penalty chargeable
(K9,000).                                      occurrence         is 300,000 penalty units
                                                                  (K90,000).
4.6 PROVIDE CLARITY ON WHEN THE
    TWO-YEAR LIMITATION PERIOD IS
    TO COMMENCE

                                                     BDO ZAMBIA - Budget 2021                  7
ZAMBIA NATIONAL BUDGET 2021 - BDO Zambia
“ Only Trusts that
      are Public Benefit
      Organisations are
      exempt from PTT

         5.0 PROPERTY TRANSFER TAX
All of the following amendments to the           5.3 FOREIGN CURRENCY
Property Transfer Tax Act will take effect           TRANSACTIONS
from 1st January, 2021.                          The amendment prescribes the exchange
                                                 rate applicable to foreign currency
5.1 REDEFINING THE REALISABLE VALUE              denominated transactions for PTT
    ON INDIRECT TRANSFER OF SHARES               purposes.
 The measure is aimed at determining the
realisable value in respect of the transfer of   5.4 APPLICATION OF PTT TO INDIRECT
shares issued by a company incorporated               FOREIGN TRANSFERS OF SHARES
outside Zambia to ensure that only               In the case of indirect share transfers , this
the Zambian proportion of the value is           measure exempts the liability to PTT where
included in the value chargeable to PTT.         the value of the transferred shares is less
                                                 than 10% of the Zambian company value.
5.2 CLARITY ON APPROVED PUBLIC
     BENEFIT ORGANISATIONS EXEMPT
     FROM PTT                                       Exchange rate applicable
This measure clarifies that only Trusts that           to foreign currency
are approved Public Benefit Organisations
are exempt from PTT.                               denominated transactions
                                                      is prescribed for PTT

 8       BDO ZAMBIA - Budget 2021
“  Renewal
    fees for licenses
    suspended for
    hotels & lodges
        6.0 TOURISM
6.1 RATE OF INCOME TAX                      6.4 SUSPENSION OF RETENTION FEES
Corporate income tax rate to be reduced     Suspension of retention fees paid by
to 15% from 35% on income earned by         tourism enterprises.
hotels and lodges on accommodation and
food services.                              6.5 SUSPENSION OF REGISTRATION
                                                FEES FOR HOTEL MANAGERS
6.2 IMPORT DUTY                             Suspension of registration fees for hotel
Import duty on safari game viewing motor    managers.
vehicles and tourist buses and coaches to
be suspended.                               6.6 IMPOSITION OF A PENALTY FOR
                                                UNDER DECLARATION ON
6.3 SUSPENSION OF RENEWAL FEES ON              TOURISM LEVY RETURNS
    LICENCES                                Tourism levy regulations to provide for
Suspension of renewal fees paid by hotels   the imposition of a penalty for under
and lodges on licences.                     declaration on tourism levy returns.

                                                Import duty on
                                                 tourist game
                                               viewing vehicles,
                                               buses & coaches
                                                  suspended

                                                   BDO ZAMBIA - Budget 2021             9
“   Excise duty on
                                                  plastic flat bags
                                                  introduced at
                                                  30%
        7.0 CUSTOMS AND EXCISE
All of the following measures will take       In January 2019, a 5% import duty was
effect from 1st January, 2021.                introduced on importation of copper
                                              ores and concentrates and this led to a
7.1 REMOVAL/REDUCTION OF IMPORT               significant rise of procurement costs for
     DUTY IN THE HORTICULTURE AND             businesses operating in the mining and
     FLORICULTURE SUBSECTORS                  processing sectors.
In an effort to enhance floriculture and
horticulture subsectors and to promote        • The import duty on importation of
other traditional exports, the following        refrigerated trucks has been suspended.
measures have been proposed:                    This measure is aimed at supporting the
                                                domestic and export markets
• Suspension of import duty on biological     • Reduction of import duty on selected
  control agents                                trimmings from 25% to 5%
• Removal of import duty on greenhouse          This is aimed at promoting the local
  plastics                                      garments and textile industry
• Reduction of import duty on selected        • Reduction of import duty on electrical
  bulb plants from 25% to 15%                   motor vehicles from 30% to 15%
• Reduction of import duty on secateurs         The proposed measure is aimed at
  from 15% to 5% and on pruners from            reducing the use of fossil fuel
  25% to 5%
• Removal of import duty on selected          7.3 MITIGATING REDUCTIONS
  agricultural clippers.                      In mitigating the revenue loss arising from
• Removal of import duty on crocodile         the above measures, the following were
  skin                                        proposed:

7.2 REMOVAL/REDUCTION OF OTHER                • Increase import duty to 40% from
     IMPORT DUTY                                25% on agro products such as beef
Further incentives for other sectors aimed      and beef processed products, chicken
at stimulating their economic activity were     and chicken processed products as well
proposed. These include:                        as fish imported from outside the SADC
                                                and COMESA regions
• The removal of import duty on copper        • Introduce excise duty at the rate K1.50
  ores and concentrates                         per litre on reconstituted milk
                                              • Harmonization of import duty rate on
This measure has been proposed to               reconstituted milk with other forms of
encourage local processing.                     milk at 15%

10       BDO ZAMBIA - Budget 2021
“ Exclude high-
                                                  value vehicles
                                                  from definition of
                                                  used vehicle
• Adjust the specific excise duty rate on      amended to provide a mechanism for an
  cigarettes to K302 per mille from K265;      intermediary to deduct the excise duty paid
• Introduce a surtax at the rate of 20% on     on airtime and in turn charge excise duty to
  Imported un-denatured ethyl alcohol          the end user.
  of an alcoholic volume strength of 80%
  or higher                                    7.8 ADVANCE TARIFF RULING
• Introduce excise duty on plastic flat bags   The Customs and Excise Act has been
  at the rate of 30%                           amended to limit advance ruling to goods
• Harmonize the import duty rates of           that are envisaged to be imported or
  cotton and polyester fabric at 15% ad        exported.
  valorem or K 1.82 per kilogram
   whichever is higher                         7.9 ASSESSMENTS AND COLLECTION OF
• Exclusion of high value motor vehicles           DUTY
   from the definition of used motor           The Customs and Excise Act has been
   vehicles and subject them to ad valorem     amended to provide for the assessment and
   import duty                                 collection of duty in convertible currencies
                                               as prescribed by the Commissioner General.
7.4 CARBON EMISSION CERTIFICATE
     VALIDITY PERIOD
Validity period of the carbon emission
certificate has been extended from 90 days
to 1 year for motor vehicles in transit or
imported temporarily.

7.5. PENALTIES FOR FALSE INVOICES
Extend penalties for false invoices, false
representation and forgery to service
providers.

7.6 PRODUCTION ALLOWANCE FOR
    TOBACCO PRODUCTS
This will provide for a production loss
allowance at 5% for tobacco products.
                                                   Import duty increased to 40% on
                                                    agro products from outside the
7.7 INTRODUCTION OF CREDIT
                                                     SADC and COMESA regions
    MECHANISM FOR AIRTIME
    INTERMEDIARIES
The Customs and Excise Act has been

                                                      BDO ZAMBIA - Budget 2021          11
“     Country by
                                                        County reporting
                                                        requirements
                                                        introduced

         8.0 TRANSFER PRICING
All of the following amendments to the           provides for amendment of the Income Tax
Transfer Pricing Act will take effect from 1st   (Transfer Pricing) (Amendment) Regulations
January 2021                                     2018 to introduce Country by Country
                                                 (CbC) reporting requirements. Introduction
8.1 INTRODUCTION OF COUNTRY BY                   of CbC reporting requirements will allow for
    COUNTRY REPORTING                            automatic exchange of corporate taxation
    REQUIREMENTS                                 data with other tax jurisdictions for entities
In order to effectively audit inter-company      operating in Zambia that are part of Multi-
transactions for compliance with transfer        National Enterprise groups.
pricing regulations, tax authorities require
good quality data on the two entities            8.2 INCREASE OF TRANSFER PRICING
involved in inter-company transactions.              DOCUMENTATION EXEMPTION
Historically, the lack of data on corporate          THRESHOLD
taxation of foreign-based related entities       Zambian companies that are not part of a
has presented a major limitation for tax         Multi-National Enterprise Group and have
authorities making it difficult to carry         turnover below K20 million are currently
out transfer pricing assessments on              exempt from the requirement to prepare
transactions between related companies.          transfer pricing documentation. The
                                                 proposal increases the exemption threshold
Taking the above into account, the proposal      from K20 million to K50 million annually.

         9.0 NON-TAX REVENUE MEASURES
• The government          private company
proposes to increase      limited by shares and
various immigration       the filing of annual
permit fees to cost       returns made on the
recovery levels           e-PACRA system have
• Discounts granted       been removed
to the public on
fees paid for online
registration of a

 12      BDO ZAMBIA - Budget 2021
“Zambia has
    over 20 double
    taxation treaties...

         10.0 DOUBLE TAXATION TREATIES
                                                     Applicable Tax Rates
          Country                                                                   Consultancy
                                    Dividends          Interest       Royalties        Fees
 Botswana                            5% or 7%             10%            10%              10%
 Canada                                15%                15%            15%              0%
 China                                  5%                10%             5%              0%
 Germany                            5% OR 15%             10%            10%              0%
 India                              5% OR 15%             10%            10%              10%
 Ireland                               7.5%               10%            10%              0%
 Italy                              5% or 15%             10%            10%              0%
 Japan                                  0%                10%            10%              0%
 Kenya                                 20%                20%            20%              0%
 Mauritius *                           TBA                TBA            TBA              TBA
 Netherlands                        5% OR 15%             10%            10%              0%
 Norway                                15%                10%            15%              0%
 Seychelles                         5% or 10%              5%            10%              0%
 South Africa                          15%                15%            20%              20%
 Sweden                             5% OR 15%             10%            10%              0%
 United Kingdom                     5% or 15%             10%             5%              0%

* The current treaty with Mauritius expires 31 December 2020. A new treaty has not yet been
negotiated

   This is a selection of countries most commonly transacted with and is not a comprehensive
   list. For further details please contact us.

   The rates available under the various DTAs are not automatic and have to be applied for.

                                                            BDO ZAMBIA - Budget 2021            13
11.0 ABOUT US

 BDO INTERNATIONAL

 US$9.6 billion                     2019 REVENUE

                     1,617 Offices
        Countries
167

                    88,000+ Staff
 * Increase from 2018: 10.1% year-over-year growth

           PROVIDING A PERSONAL AND VALUE-FOR-MONEY
           SERVICE THROUGH CONSTRUCTIVE AND EFFECTIVE
           ADVICE, FINANCIAL PLANNING AND CONTROL.

     BDO Zambia                           is a firm of public accountants, registered with the
                                          Zambia Institute of Chartered Accountants, providing
     audit, accounting, taxation, management and consulting services to some five hundred
     clients of varying sizes and needs. BDO Zambia is part of the BDO International network.

     Presently with 6 Partners and over 100 professional and administrative staff in our Lusaka
     offices, the Firm places particular emphasis on providing a personal and value for money
     service, through constructive and effective advice and financial planning and control.
     In addition to our own team of financial experts, the Firm has a number of qualified
     professionals providing advice on matters such as Human Resources Management and Legal
     Draftsmanship.

     We have cut out needless bureaucracy, so we can serve you responsively and flexibly. Our
     systems work to support our people, not the other way around. That gives us more time to
     get to know you and your business – and give more relevant, intelligent advice.

     With the backing of the BDO international network, we are able to combine global coverage
     with local knowledge. Our close relationship with BDO South Africa and BDO UK provides
     us with additional resources and expertise to meet business requirements in Zambia.

     The Partners, Directors and staff of BDO Zambia have established the Firm and its
     related specialised business entities as the preferred provider of Financial Services in the
     country. We have a commitment to total and exceptional client service and we build an
     understanding of our clients’ businesses that allows us to play an active role in their success.

14             BDO ZAMBIA - Budget 2021
YOUR BDO TEAM
  LEADING THE WAY

  William Saunders             Douglas Ironside               Deborah Nonde
     Senior Partner            Managing Partner                  Tax Partner
william.saunders@bdo.co.zm   douglas.ironside@bdo.co.zm      debbie.nonde@bdo.co.zm

   Katrina Mabika             Godsave Nhekede                 Tinashe Jerahuni
     Tax Partner                  Audit Partner                 Audit Partner
katrina.mabika@bdo.co.zm     godsave.nhekede@bdo.co.zm     tinashe.jerahuni@bdo.co.zm

                                                   BDO ZAMBIA - Budget 2021             15
OUR COMMITMENT TO SERVICE
       EXCELLENCE, PROFESSIONALISM AND
      CLIENT SATISFACTION HAS POSITIONED
     US SECURELY AS ONE OF THE LEADING TAX
      AND ACCOUNTING ORGANISATIONS IN
                   THE WORLD.

     YOUR BDO TAX MANAGERS

                  Kafumu Mbewe            Stanley Madabbwa
               kafumu.mbewe@bdo.co.zm   stanley.madabbwa@bdo.co.zm

16     BDO ZAMBIA - Budget 2021
Z A M B I A TA X TA B L E S 2 0 2 1
                           (12 months ending 31 December 2021)

PERSONAL TAXATION (Monthly)                      Industrial buildings
0 - K4,000                    0%                   * investment allowance             10%
K4,001 – K4,800              25%                   *initial allowance                 10%
K4,801 – K6,900		           30%                    *annual allowance                   5%
Above K6,900               37.5%                 Commercial buildings                  2%
                                                 Farm works & improvements           100%
Tax credit for differently abled                 Equipment used in farming &
persons 			                          K500        agro-processing                    100%
                                                 Equipment used in
Car Benefits                                     manufacturing,
 *2800cc & above                   K40,000       tourism & generation
 *1800cc to 2799cc                 K30,000       of electricity    		                50%
 *Up to 1799cc                     K18,000       For leasing companies -
                                                 equipment leased out under
BUSINESS TAXATION                                an operating lease                  50%
RATE                                             Improvement allowance in
Corporate Income Tax               35%           an MFEZ 		                         100%
Farming & agro-processing          10%           Development allowance on
Manufacture of organic &                         growing of roses, tea, coffee,
chemical fertilizers               15%           banana plants       		              10%
Tourism (Accommodation &                         The number of years for claiming
Food)       		                     15%           development allowance              5 years
Mining Operations -                              Mining sector for assets
  *Profit up to 8%                30%            in use           		                 20%
  *Profit above 8%           up to 45%
Mineral processing                 35%           WITHHOLDING TAX
Companies that add value                         Rental income (final tax)           10%
to copper cathodes                 15%           Commission to non-employees         15%
Non-traditional exports            15%           Royalties, management &
Export of cotton without                         consultancy 		                      15%
a permit       		                  35%           Dividends & interest
Income on commercial                             			                                 15%
activities of Public benefit                     Dividends for companies
organisations                      15%           carrying on mining operations         Nil
Turnover Tax                        4%
(for annual turnover below                       WHT FOREIGN ENTITIES
K800,000) Telecommunication                      Commissions		                       20%
Companies -                                      Royalties, management &
  *First K250,000                 35%            consultancy fees                    20%
  *Above K250,000                  40%           Dividends, interest and
                                                 branch profits 		                   20%
Tax losses can be carried forward                Payments to non-resident
for up to 5 years                                entertainers & sports persons       20%
(10 years for companies in the                   Government Securities               15%
energy & mining sector)

Annual allowance to employer
for employing a person with a
disability 		                       K2,000

CAPITAL ALLOWANCES
RATE
Plant, machinery & commercial
vehicles                              25%
Non-commercial vehicles               20%

                                                    BDO ZAMBIA - Budget 2021
BDO Zambia Limited is a member of BDO International Limited,
        a UK company limited by guarantee.

        BDO is the brand name for the BDO International network and for
        each of the BDO member firms.

        www.bdo.co.zm

CONTACT US AT
BDO Lusaka                      Tel: +260 211 252 836 /
Gallery Office Park                  250 222 / 250 631
Lagos Road, Rhodes Park         tax@bdo.co.zm
PO Box 35139                    www.bdo.co.zm
Lusaka, Zambia

        The information contained in this document and the enclosed
        bookmark is based on the Budget Address presented by the Minister
        of Finance, Honourable Dr. Bwalya Ng’andu, MP. This document
        provides an overview of the announcements made in the speech
        and information provided by the Zambia Revenue Authority. Whilst
        every effort has been made to ensure its accuracy, we are unable
        to accept responsibility for errors and omissions. It should be noted
        that the measures as introduced by the Budget Address are subject
        to Parliamentary approval. No financial decisions should be made
        based solely on the information contained herewith and no liability
        will be accepted for decisions based on its contents without further
        consultation with an official representative of BDO Zambia Limited.
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