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Reconciling Global Norms and Local Realities: An Assessment of Zambia’s Legislative and Institutional Framework on Transfer Pricing Regulation

Author

Listed:
  • Victor Mwape

    (University of Zambia, Institute of Distance Education, Lusaka, Zambia)

  • Austin Mwange

    (The University of Zambia, Graduate School of Business, Lusaka, Zambia)

  • Munyonzwe Hamalengwa

    (School of Law, Zambia Open University, Lusaka, Zambia)

Abstract

Transfer pricing (TP) regulation has become a central concern in global tax governance, particularly in resource-rich developing countries susceptible to base erosion and profit shifting by multinational enterprises (MNEs). This article critically evaluates Zambia’s legislative and institutional framework for transfer pricing, focusing on its alignment with the OECD Transfer Pricing Guidelines and the United Nations Practical Manual. Drawing upon Zambia’s Income Tax Act, statutory instruments, practice notes, and the evolution of regulatory amendments from 1999 to 2023, the study explores the legal, administrative, and practical implications of enforcing the arm’s length principle (ALP). The findings reveal that although Zambia has adopted many international best practices, its enforcement regime remains weakened by limited administrative capacity, legislative fragmentation, data inaccessibility, and insufficient penalties. Using a comparative doctrinal method, the article underscores the need for contextual legal reforms and capacity-building mechanisms to improve the effectiveness of TP governance in Zambia and other similarly situated African jurisdictions.

Suggested Citation

  • Victor Mwape & Austin Mwange & Munyonzwe Hamalengwa, 2025. "Reconciling Global Norms and Local Realities: An Assessment of Zambia’s Legislative and Institutional Framework on Transfer Pricing Regulation," African Journal of Commercial Studies, African Journal of Commercial Studies, vol. 6(2).
  • Handle: RePEc:cwk:ajocsk:2025-53
    DOI: 10.59413/ajocs/v6.i2.20
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    Keywords

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    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

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