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

Abstract

Article Info 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 Volume 6, Issue 2 shifting by multinational enterprises (MNEs). This article critically evaluates Zambia’s legislative and institutional framework for transfer pricing, focusing on its alignment with Publication history: the OECD Transfer Pricing Guidelines and the United Nations Practical Manual. Drawing Accepted on 24 April 2025; upon Zambia’s Income Tax Act, statutory instruments, practice notes, and the evolution of Published: 29 April 2025 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 Article DOI: although Zambia has adopted many international best practices, its enforcement regime 10.59413/ajocs/v6.i2.20 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