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A Tax Clearance Certificate can determine whether a business proceeds with a procurement bid, satisfies a regulatory request or completes a commercial transaction. From 16 September 2026, the Zambia Revenue Authority, ZRA, has made its position clear: a PACRA-registered business must hold the tax registrations that match its operations before ZRA will issue or maintain a zra tax clearance certificate.
The measure responds to entities that register with the Patents and Companies Registration Agency, PACRA, obtain a Taxpayer Identification Number, TPIN, and then fail to open the tax accounts their activities require. ZRA has linked this gap to tax evasion risks, shell-company arrangements and illicit financial flows.
For directors, investors and compliance leaders, the immediate task is practical. Compare the company’s actual revenue streams, staff profile and trading activity against the tax types registered under its TPIN. A TPIN alone will no longer support tax-clearance status where the underlying registrations and compliance record do not align.
What ZRA changed on 16 September 2026
In its 16 September 2026 statement, ZRA confirmed that it is strengthening system controls around Tax Clearance Certificates. Going forward, ZRA will issue a TCC only where a business has registered for the tax types applicable to its operations and meets its related tax obligations.
This change targets business-related TPINs that arise from PACRA registrations. ZRA specifically stated that it does not apply to individuals who hold TPINs in their personal capacity.
The Authority did not present the measure as a new tax. It is a compliance-control measure that connects three records which businesses sometimes treat separately: PACRA company registration, the ZRA taxpayer register and the tax-clearance process.
Why the control matters
A TCC carries weight in Zambia because commercial counterparties, regulators and procuring entities rely on it as evidence of tax compliance. ZRA wants the certificate to confirm more than the existence of a TPIN.
Under the enhanced control, a company that trades, employs staff or earns taxable income without the relevant tax account may not obtain or retain clearance. This can create an immediate operational issue when a client, bank, public procurement process or licensing authority requests current tax-clearance evidence.
ZRA has also cited analysis of Suspicious Transaction Reports submitted by the Financial Intelligence Centre, FIC. That analysis identified cases in which PACRA-registered entities with TPINs conducted financial transactions despite holding no appropriate tax accounts with ZRA.
The business risk behind a TPIN without tax accounts
Many companies obtain a TPIN during incorporation and assume that the registration process is complete. In practice, PACRA registration establishes the legal entity, while ZRA tax registration must reflect what that entity actually does.
A dormant company and an operating company require different compliance attention. A genuinely inactive entity should maintain records that support its status. An entity that invoices customers, imports goods, employs people or receives business income must ensure that its ZRA profile reflects those activities.
ZRA’s announcement focuses on businesses that continue commercial activity without the corresponding tax accounts. The Authority has identified this pattern as a route through which parties may conceal taxable activity or use entities as conduits for illicit financial flows.
A practical example
Consider a company incorporated through PACRA in Lusaka that has a TPIN but begins providing professional services in 2026. If it invoices clients and engages employees, its directors should not assume that the incorporation record and TPIN will satisfy ZRA’s tax-clearance controls.
The company must identify the taxes that its services, payroll and transaction profile trigger, register for the applicable tax types, submit required returns and settle obligations due. The exact registration position depends on the facts of the business, its turnover, contracts and workforce.
We recommend that management document this review. A short board or management paper that records activities, relevant registrations, filing status and outstanding actions gives the business a clear audit trail when it seeks a TCC or responds to a ZRA query.
Tax registrations to review before seeking clearance
The correct tax types vary by enterprise. A manufacturer in the Copperbelt, a mining contractor, an importer at Nakonde and a technology services company in Lusaka may have different registration requirements.
ZRA’s 16 September 2026 notice does not list a standard set of tax accounts for every PACRA-registered business. It requires each business to register for the tax types applicable to its operations. That distinction matters.
Your review should consider the following areas.
Income and corporate tax position
Review whether the entity earns business income and whether its income-tax registration, returns and payments reflect its current activity. A company that has moved from pre-revenue operations to active trading should update its compliance position before it needs a TCC for a transaction.
Payroll and employment obligations
Where the business employs staff, directors should confirm that payroll-related registrations and remittances match the workforce and payroll records. Payroll data often reveals gaps between declared activity and actual operations.
Use our Zambia PAYE calculator as an initial planning tool. Your payroll team should still obtain qualified review of applicable rates, thresholds, deductions and filing obligations before making submissions.
Indirect taxes and transaction-based obligations
Businesses that supply goods or services, import products, make regulated payments or operate in specialised sectors may trigger indirect or transaction-based tax obligations. The applicable treatment depends on the activity and transaction structure, not simply on the company name recorded at PACRA.
Directors should map each material revenue line to its tax treatment. They should also review contracts, invoices, customs documentation and bank flows against the tax accounts held under the company’s TPIN.
Sector-specific treatment
Mining, financial services, construction, telecommunications, transport and cross-border trade can each raise additional tax and regulatory questions. A single generic registration review may overlook obligations linked to withholding, imports, licences or project-based operations.
International groups should pay close attention where a Zambian subsidiary, branch, project office or local agent begins activity before the group has completed its local tax setup. The operating model needs to align with both the PACRA record and the ZRA taxpayer profile.
Publication note: Tax registrations, filing periods, tax rates and statutory thresholds require review by a qualified M&J team member before publication or implementation. ZRA requirements can change through legislation, public notices and administrative practice.
A 30-day response plan for directors and compliance teams
The new control rewards businesses that can show a coherent record. We suggest a focused review rather than waiting until a tender, contract renewal or financing transaction requires a TCC.
1. Reconcile PACRA, TPIN and operating records
Start with the legal entity documents held at PACRA, the TPIN record and the current business profile. Confirm the company name, registration details, directors, business activities and physical operating footprint.
Then compare those records with invoices, customer contracts, payroll, bank account activity and management accounts. The objective is to identify where the enterprise’s real activity has moved ahead of its tax registrations.
2. Build a tax-account matrix
Prepare a simple matrix listing each revenue stream, employee category, import activity and major payment type. Against each item, record the relevant tax account, registration status, return status, payment position and owner within the business.
This exercise helps management distinguish an administrative omission from a wider compliance gap. It also gives external advisers and ZRA a factual starting point if regularisation is required.
3. Address outstanding returns and liabilities
Tax clearance depends on compliance obligations as well as registration. A business that opens the correct accounts but leaves returns unfiled or liabilities unresolved may still face difficulty obtaining its TCC.
Assess outstanding periods, reconcile tax records to the general ledger and establish the amount at issue before engaging ZRA. Where the facts are complex, a structured voluntary regularisation plan can protect decision-making and reduce avoidable disruption.
4. Assign ownership at executive level
Finance teams often manage tax filings, but TCC risk can affect sales, procurement, project delivery and banking relationships. The CFO, finance director or designated compliance lead should own the register review and report material gaps to the board.
This is especially important for groups with multiple PACRA entities. One inactive company, special-purpose vehicle or newly acquired subsidiary can create risk if it conducts transactions without the matching ZRA tax registrations.
For a broader review of controls, see our tax compliance advisory services. We help enterprises connect statutory obligations with commercial priorities and governance reporting.
Change log: ZRA Tax Clearance Certificate controls
| Date | Development | Business implication |
|---|---|---|
| 16 September 2026 | ZRA announced enhanced system controls for Tax Clearance Certificates. | Businesses should review registration status before requesting or renewing tax clearance. |
| 16 September 2026 | ZRA confirmed that a TCC will be issued only where applicable tax types are registered and obligations are met. | A TPIN without relevant tax accounts may not support TCC issuance or maintenance. |
| 16 September 2026 | ZRA cited PACRA registrations, TPINs and FIC Suspicious Transaction Reports as part of the risk context. | Directors should reconcile corporate, tax and transaction records. |
| 16 September 2026 | ZRA clarified that the measure targets business-related TPINs arising from PACRA registration. | Individuals holding TPINs in a personal capacity fall outside this stated measure. |
Frequently Asked Questions
Does every PACRA-registered company need a ZRA Tax Clearance Certificate?
Not every company may need to present a TCC at every stage of its life. However, ZRA describes the certificate as an important instrument in commercial, regulatory and procurement transactions. Any company likely to tender, contract with institutional clients or meet regulatory requirements should maintain a clear tax-compliance position.
Can a business obtain a TCC with a TPIN only?
No. Under ZRA’s 16 September 2026 announcement, a business must also hold the tax registrations applicable to its operations and comply with related tax obligations. A TPIN by itself does not establish tax-clearance eligibility.
Does the new control apply to personal TPINs?
ZRA has stated that this measure applies to business-related TPINs arising from PACRA business registration. It does not apply to individuals who hold TPINs in their personal capacity.
What should an inactive company do?
An inactive company should confirm that it is genuinely inactive and retain evidence supporting that position. If the company has begun invoicing, receiving business income, employing people or conducting transactions, its directors should review the relevant ZRA registrations without delay.
Tax clearance now depends on whether your legal registration, tax accounts and actual operations tell the same story. Speak With Our Team to arrange a Zambia tax-registration and TCC readiness review.