The Zambian tax authority released Practice Note No. 2/2018 on Transfer Pricing and Documentation Rules in late November 2018 to provide guidance in relation to the changes made by the Income Tax (Transfer Pricing) (Amendment) Regulations, 2018 ({News-2018-04-23/A/6-previous coverage}). This includes further details on:
- The principle of comparability, which should be based on the following factors:
- Characteristics of the property or services;
- Functions undertaken;
- The contractual terms of t…