Zambia has introduced a tax amnesty, the Extended Voluntary Disclosure Scheme, under which interest and penalties are waived in full where the underlying tax is paid by 31 December 2026.
Zambia has introduced a tax amnesty which may be useful for some taxpayers.
It is called the Extended Voluntary Disclosure Scheme, and it operates from 17 September to 31 December 2026.
If the tax owed is paid by 31 December 2026, the full interest and penalties will be waived. The scheme covers liabilities that arose before 31 August 2026.
It can apply even where the tax itself was previously paid, but interest and penalties are still owed. That is a useful point, and an easy one to miss, because a taxpayer in that position may not think of itself as having a disclosure to make at all.
Which Taxes Are Covered
The scheme covers a wide range of taxes, including:
- income tax;
- PAYE;
- VAT;
- mineral royalties;
- withholding tax;
- property transfer tax;
- betting levy;
- tourism levy; and
- unpaid customs duties.
That is a broad list, and notably it reaches beyond the main direct and indirect taxes into the sector-specific levies and into customs.
The Conditions That Have to Be Met
The waiver is proportionate to what is paid. If only part of the taxes owed are paid, only the same portion of the interest and penalties will be waived.
All outstanding tax returns must be filed.
For VAT, Smart Invoice, the Zambia Revenue Authority’s electronic invoicing system, must be used.
In our view the return-filing condition is the sensible one to look at first, because it is the condition most likely to take time. A taxpayer that has fallen behind on tax will very often have fallen behind on returns as well, and the returns have to be brought up to date before the waiver is available.
What Falls Outside the Scheme
Cases that are already under investigation for fraud, wilful default or other tax offences are not eligible for the waiver.
Fines and penalties that have already been paid will not be refunded.
Penalties that have arisen after 31 August 2026 are also not included in the scheme.
Disputes Already Before a Court or Tribunal
Disputes before a court or the tax appeal tribunal can be included, provided the tax is paid and the taxpayer withdraws its case.
This is a genuine decision to make rather than a formality. A taxpayer with a live dispute has to weigh the certainty of a full waiver of interest and penalties against whatever prospect it has of succeeding on the tax itself.
How to Apply
Applications can be made in writing to a taxpayer’s local Zambia Revenue Authority office, or by email to an email address dedicated to the scheme.
The Commercial Implications
Taxpayers with Known Arrears
For a taxpayer that already knows it owes tax for a period before 31 August 2026, the arithmetic is simple. Paying the tax by 31 December 2026 removes the interest and penalties entirely.
Since the waiver is proportionate, a taxpayer that can only fund part of the liability still gets the benefit on that part, so partial payment is worth making rather than leaving until the taxpayer can pay in full.
Taxpayers Who Have Paid the Tax but Still Owe Interest and Penalties
This group is the one most likely to overlook the scheme, because the tax has been settled and the remaining balance looks like an administrative leftover.
The scheme applies to them, and for them the whole of the outstanding amount is what is waived.
Taxpayers Behind on Returns
Outstanding returns have to be filed, and for VAT, Smart Invoice has to be in use. Both take preparation.
With the scheme closing on 31 December 2026, a taxpayer with several periods of unfiled returns has a little over three months in which to file them, fund the tax and apply.
Taxpayers in Dispute
A taxpayer with a matter before a court or the tax appeal tribunal can bring it into the scheme, but only by paying the tax and withdrawing the case. That is a commercial judgment about the strength of the case, and it is worth taking advice on before the deadline rather than at it.
Looking Ahead
Amnesties of this kind are a familiar instrument, and their appeal to a revenue authority is obvious: they bring in cash, they clear old debt off the books, and they pull non-compliant taxpayers into the filing system without the cost of pursuing each one.
The features we would particularly welcome here are the proportionate waiver, which means a taxpayer who cannot pay everything is not shut out altogether, and the inclusion of taxpayers who have paid the tax but still carry interest and penalties.
The exclusion of cases already under investigation for fraud or wilful default is the right line to draw. An amnesty that covered those cases would reward the taxpayers who behaved worst.
The obvious constraint is time. The scheme opened on 17 September 2026 and closes on 31 December 2026, and the conditions attached to it, particularly the filing of outstanding returns, are not conditions that can be met in the last week. Any taxpayer who thinks the scheme might apply should be working out its position now rather than in December.
If you would like to discuss whether the Extended Voluntary Disclosure Scheme could apply to your Zambian tax position, our team would be glad to help. Get in touch.
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