A supplier can win a tender on Monday and still lose momentum by Wednesday because its tax clearance has expired. The pressure increases when the ZRA account shows unpaid principal tax, penalties or interest, particularly where a property transfer, licence or supplier onboarding process needs evidence of compliance.

A ZRA tax clearance certificate (TCC) does not always require every historical liability to be paid before you apply. Since 1 January 2025, the Income Tax Act has allowed a certificate where a taxpayer has fulfilled its obligations or has made arrangements satisfactory to the Commissioner-General. Our ZRA tax clearance certificate (TCC) guide explains the wider process, while this guide focuses on what to do when debt remains on the account.

The judgement call matters. Do not assume that submitting a payment-plan request guarantees a TCC. ZRA must accept the arrangement, and you must continue to honour it.

Start by separating the liability from the certificate

A TCC confirms the position that ZRA is prepared to certify for the period stated on the certificate. It does not erase a tax debt, replace a payment arrangement or settle a different regulator’s compliance requirement.

This distinction prevents a common and costly mistake. PACRA annual-return compliance, for example, is separate from ZRA tax compliance. A company can file its PACRA annual return and still have a ZRA liability that affects its TCC application.

The same applies to NAPSA. NAPSA issues its own employer compliance certificate through iCARE, so a ZRA TCC is not evidence of NAPSA compliance. Keep the documents separate in your tender, licensing and governance files.

Check what is actually outstanding

Before requesting a payment arrangement, review each outstanding item in TaxOnline. Establish whether the balance consists of principal tax, accrued penalties, accrued interest, unfiled returns, an assessment you intend to challenge, or a payment that has not yet reflected.

This step determines the right conversation with ZRA. A business that owes principal tax needs a funding and repayment plan. A business with a balance caused by an unprocessed payment needs proof of payment and account reconciliation instead.

Do not request a TCC first and investigate later. An unresolved return or unexplained assessment can hold up the application even where management has money available to pay.

Understand the route available when tax remains due

The legal position changed on 1 January 2025. The statutory definition of a tax clearance certificate now recognises a taxpayer who has either fulfilled obligations or made arrangements satisfactory to the Commissioner-General.

That wording creates an avenue for a business with outstanding ZRA liabilities. It does not create an entitlement. The Commissioner-General must consider the arrangement satisfactory, which is why the quality of the request and the business’s payment record matter.

1. Settle the principal tax where the business can do so

Full settlement of principal tax remains the clearest route. It removes uncertainty around the debt and gives ZRA a cleaner compliance position to assess.

As of 30 September 2026, ZRA’s Extended Voluntary Disclosure Scheme runs from 17 September 2026 to 31 December 2026. ZRA states that it offers a 100 percent waiver of accrued penalties and interest where the taxpayer settles the principal tax due, subject to the scheme conditions.

The date matters. A business considering voluntary disclosure in November 2026 should quantify the principal tax and test its cash position promptly, because the published scheme ends on 31 December 2026.

Do not promise your board that a payment plan alone secures the waiver. ZRA’s published information links the stated waiver to settlement of principal tax, and the conditions require confirmation before you rely on them.

2. Apply for a Time to Pay Agreement

Where immediate full settlement would damage working capital, explore a Time to Pay Agreement, often called a TPA, through the TaxOnline compliance functions. ZRA’s 2026 voluntary-disclosure guide confirms that taxpayers may pay principal tax in full or apply for a TPA.

The published guide does not specify a standard instalment percentage, security requirement, form number or approval timeframe. Do not build your forecast around an assumed 10 percent deposit, a six-month term or automatic approval unless ZRA has confirmed those terms for your account.

A credible request should show the debt by tax type, the amount available immediately, realistic instalment dates, and the cash flow that supports them. The purpose is practical: ZRA needs to see an arrangement that the enterprise can honour, not an optimistic proposal that misses its first payment.

Worked example: a contractor facing supplier onboarding

Take a Lusaka engineering contractor with K900,000 in outstanding principal tax and K240,000 in accrued penalties and interest. The company expects a K1.8 million customer payment in 45 days, but its prospective customer requires a current TCC before completing supplier onboarding.

Management should first confirm whether all returns are filed, then calculate what it can pay without missing payroll and supplier commitments. If it applies for a TPA, the proposal should reflect actual receivables, not a hopeful sales pipeline, because a missed instalment can undermine confidence in the arrangement.

If the liability falls within the Extended Voluntary Disclosure Scheme, the company should also test whether it can settle principal tax by 31 December 2026 and qualify for the stated penalty-and-interest waiver. It would spend more time up front on account reconciliation than many businesses do, but that work could prevent it from negotiating a repayment plan against an incorrect balance.

3. Resolve filing gaps and account errors first

A payment plan does not cure missing returns. If VAT, income tax, PAYE or another tax obligation remains unfiled, resolve that compliance gap alongside the debt discussion.

This is the step many businesses skip. They focus on the headline debt figure, then discover that an unfiled return, a late payment posting or a mismatch on the account prevents ZRA from treating the record as compliant.

Where you disagree with an assessment, document the basis clearly and obtain professional tax advice before you submit a payment proposal. Do not simply ignore the assessment while expecting a TCC to issue.

Apply for the certificate through TaxOnline

Once you have checked the account and addressed the immediate compliance issues, submit the TCC application through ZRA TaxOnline. Use the TPIN and password for the correct taxpayer account.

Follow these steps:

1.       Log in to ZRA TaxOnline using the business TPIN and password.

2.       Select Compliance.

3.       Select Tax Clearance Certificate.

4.       Select Apply.

5.       Review the application details before submission and retain the submission record.

6.       Where ZRA approves the application, generate, print or save the certificate through the portal.

ZRA Practice Note No. 1 of 2025 confirms this portal process. It matters because an informal request, an email chain or a copy of an old certificate does not replace the TaxOnline application.

ZRA’s Taxpayer Charter states that it will issue a tax clearance within 48 hours after receiving an application. Treat 48 hours as a service target, not a guarantee of approval where the account has unresolved liabilities, returns or compliance questions.

Check the certificate before you send it out

Read the validity period shown on the certificate. The relevant period is the one printed on the document, not the date your team assumes it will expire.

This matters for contracts and property transactions. If a certificate is cancelled, the cancellation takes effect when ZRA serves notice, and the holder must return the cancelled certificate within 30 days.

Maintain a register showing the certificate number, issue date, stated validity period, the business unit using it and the person responsible for renewal. This is basic tax governance, particularly where procurement teams submit documents without checking their current status.

Worked example: a retailer with a cash-flow gap

Take a retailer with twelve staff, monthly payroll of US$40,000 and an outstanding ZRA balance that includes principal tax plus penalties and interest. The owners want a TCC because a landlord has asked for current compliance documents before renewing a warehouse lease.

The wrong approach is to pay a token amount, apply immediately and tell the landlord that approval is certain. The better approach is to reconcile the account, confirm all returns, assess whether the 2026 voluntary-disclosure window applies, and submit a payment arrangement that the retailer can maintain through the next trading cycle.

If the business can settle principal tax before 31 December 2026, it should compare that cash requirement against the stated 100 percent waiver of accrued penalties and interest. If it cannot, it should seek a TPA without representing that the arrangement automatically guarantees a TCC.

Avoid the four errors that delay a TCC

Treating a payment arrangement as automatic approval

A TPA is an option to explore, not a promise of a certificate. The law requires arrangements satisfactory to the Commissioner-General, so keep every agreed payment current and respond promptly to any ZRA query.

Mixing ZRA, PACRA and NAPSA documents

PACRA annual returns, a ZRA TCC and a NAPSA iCARE compliance certificate serve different purposes. Prepare each one for the relevant counterparty rather than assuming one certificate covers every regulatory obligation.

Relying on an expired certificate

A previous TCC may have helped with a transaction last month, but its stated validity period controls. Check the current document before presenting it to a customer, licensing authority or buyer.

Claiming relief before checking the scheme conditions

The Extended Voluntary Disclosure Scheme has a defined period from 17 September 2026 to 31 December 2026. Confirm eligibility and settlement conditions with ZRA before you record a penalty or interest waiver in management accounts.

Build a stronger compliance file for 2026

For businesses that regularly tender, transfer property or work with large customers, TCC management should sit within the finance calendar. Assign ownership to a named finance leader, set reminders before the certificate’s stated expiry date, and reconcile TaxOnline balances every month.

Where a liability exists, prepare the repayment case before an urgent transaction forces the issue. A board that sees the principal tax, penalties, interest, filing status and available cash can make a better decision than one presented with a single overdue balance.

We recommend a professional review where the liability is material, the account contains several tax types, or the business plans to rely on the Extended Voluntary Disclosure Scheme. Statutory positions and scheme conditions can change, so an M&J team member should review this guidance before publication or reliance.

Frequently Asked Questions

Can I get a ZRA TCC if I still owe tax?

Potentially. From 1 January 2025, the Income Tax Act allows a TCC where a taxpayer has fulfilled obligations or made arrangements satisfactory to the Commissioner-General. A payment arrangement does not guarantee approval.

How long does ZRA take to issue a TCC?

ZRA’s Taxpayer Charter states a 48-hour service target after it receives an application. That target does not guarantee approval where compliance issues remain unresolved.

Can a NAPSA compliance certificate replace a ZRA TCC?

No. NAPSA issues employer compliance certificates through iCARE, while ZRA issues TCCs through TaxOnline. Keep both where a tender or transaction requires them.

Does PACRA annual-return compliance clear my ZRA tax debt?

No. PACRA annual returns and ZRA tax liabilities are separate obligations. A company can meet its PACRA filing obligation and still need to resolve a ZRA balance before pursuing a TCC.

For a structured review of your position, payment-plan options and the TaxOnline application process, visit the ZRA TCC guide for further guidance.