A finance director discovers that PAYE returns for two prior periods omitted a taxable allowance. The immediate question is not whether the error can be corrected. It is whether ZRA has already found it.

The ZRA voluntary disclosure process gives qualifying taxpayers a statutory route to regularise certain income-tax errors before Zambia Revenue Authority detects them. From 1 January 2026, section 91A of the Income Tax Act provides for a permanent Voluntary Disclosure Programme, or VDP. It can remove penalties, but it does not remove the principal tax and it does not automatically remove interest.

For boards, investors and business owners, timing matters as much as accuracy. A corrected return filed after ZRA has issued an audit notice, assessment, investigation notice or enforcement action for the relevant period will not meet the programme’s voluntary condition.

What the current ZRA Voluntary Disclosure Programme covers

ZRA’s current VDP applies to taxes administered under the Income Tax Act. These include corporate income tax, turnover tax, PAYE, withholding tax, mineral royalty, rental tax and advance income tax.

That scope matters. Do not assume that a VAT error, customs liability, excise matter or property transfer tax issue qualifies under section 91A. The current ZRA guide frames the programme around Income Tax Act taxes, so a business should separate income-tax exposures from other tax exposures before it submits anything.

The programme became effective on 1 January 2026 under section 91A, inserted by the Income Tax (Amendment) (No. 2) Act No. 17 of 2025. It has no stated closing date. However, the practical deadline is earlier than any calendar date: disclosure must reach ZRA before the Commissioner-General identifies the error.

The benefit, and its limits

A qualifying disclosure attracts a full waiver of penalties. That protection can materially reduce the cost of correcting an old PAYE, withholding tax or corporate income-tax position.

Principal tax remains payable. Interest also generally remains payable unless the Income Tax Act separately exempts it. A disclosure is therefore a compliance decision, not a way to negotiate away the underlying tax debt.

If cash flow prevents an immediate full payment, ZRA may accept an approved Time to Pay Agreement. This option matters for enterprises that can establish the full liability but need a controlled payment plan to protect working capital.

Do not confuse the VDP with the extended tax amnesty

Many taxpayers still refer to an “extended voluntary disclosure programme” when they mean the 2022/23 Tax Amnesty. That amnesty was extended from 31 March 2023 to 30 June 2023, and it is closed.

The historical amnesty waived penalties, fees and interest on eligible liabilities accrued up to 30 September 2022, subject to its conditions. It covered listed direct and indirect taxes, including VAT and local excise, and required an application through TaxOnline II, updated taxpayer details, complete current returns and a payment toward principal tax.

The current mechanism differs in two important ways. Section 91A is a permanent statutory VDP for qualifying income-tax disclosures, while the 2022/23 relief was a temporary amnesty. The current VDP waives qualifying penalties, whereas the expired amnesty could waive eligible interest and penalties.

Do not build a tax-compliance decision around a programme that ended on 30 June 2023. If the matter concerns VAT, customs or excise, obtain specific advice before describing it as a section 91A voluntary disclosure.

Step 1: Establish whether your disclosure is still voluntary

Start with the affected tax type and period. Then check every communication received from ZRA, including audit notices, assessments, investigation correspondence and enforcement communications.

A valid disclosure requires that ZRA has not issued an audit notice, assessment, investigation or enforcement action for the affected period. The rule protects the distinction between a taxpayer coming forward and a taxpayer responding after detection.

This is the step businesses skip most often. A finance team may focus on whether it can amend a return, while overlooking a letter sent to a former tax manager or an item already raised in an ongoing audit file.

Take an illustrative Lusaka distribution business with 18 employees and a monthly payroll of K420,000. During a payroll review, it finds that a recurring allowance was omitted from PAYE calculations over six months, producing an estimated K120,000 principal exposure before interest. If it has received no ZRA audit or enforcement contact for those months, it should quantify the issue and consider disclosure before filing a bare correction.

If the same business had already received an audit notice covering those six months, section 91A would not provide the same route for that period. Its better course is to respond accurately through the audit process and obtain advice on the available settlement position.

Step 2: Reconstruct every affected period

The disclosure must contain full and accurate facts for every affected period. Do not disclose one month where the same error affected a full tax year, or identify an under-declared amount without showing how the figure arose.

For PAYE, reconcile payroll registers, employee earnings, taxable benefits, remittance records and filed returns. For corporate income tax, reconcile the tax computation to management accounts, audited financial statements where available, ledgers and supporting schedules.

For withholding tax, trace the payment, the nature of the service or income, the recipient and the tax treatment applied. The point is not to create a large file for its own sake. ZRA needs documents that allow it to verify the computation.

A useful internal control is a period-by-period schedule with five columns: amount originally declared, corrected amount, difference, principal tax due and evidence held. This gives the board a clear approval record and gives the tax team a disciplined basis for its written application.

Consider an illustrative Copperbelt contractor that discovers it treated certain payments to service providers inconsistently across four quarters. Its initial estimate shows K250,000 in additional withholding tax, plus interest that it must calculate and budget for. The business should not disclose only the quarter with the largest variance if the same classification error runs through all four quarters.

It should assemble contracts, invoices, payment vouchers, tax computations and the relevant returns. If management could revisit the issue, it would identify the classification question when it first approves supplier onboarding, rather than wait until year-end reconciliations reveal the pattern.

Step 3: Prepare the written application to ZRA

There is no prescribed ZRA form in the current voluntary disclosure guide. The taxpayer submits a written application to the Regional Director, Domestic Taxes Division.

The application should identify the error, affected tax type, affected periods, computation and supporting evidence. A corrected return alone does not meet the full process described in ZRA’s guide because the written disclosure explains the error and provides the verification trail.

Keep the application factual. State what was filed, what was incorrect, what the corrected position is and how the business calculated the difference. Avoid unsupported conclusions about eligibility, particularly where ZRA contact may have occurred in relation to another period or tax type.

Before submission, make sure the company name, TPIN details and tax periods align across the letter, returns, payment schedule and evidence pack. Small identity mismatches can slow down a matter that already depends on proving the disclosure came before detection.

Step 4: File or amend returns through ZRA TaxOnline

After preparing the disclosure, file or amend the relevant returns and arrange payment through ZRA TaxOnline. The written application, return position and payment plan should tell the same story.

If the enterprise can pay the full principal tax, document that payment arrangement clearly. If it cannot, engage on a Time to Pay Agreement rather than assuming that an intended future payment satisfies the programme.

An approved Time to Pay Agreement can satisfy the payment condition. An informal internal promise to pay cannot provide the same certainty, because the current guide requires full principal-tax payment or an approved agreement.

Run the numbers through a PAYE calculator before finalising a payroll-related disclosure, then reconcile the output to actual payroll records. A calculator helps test arithmetic. It does not decide whether an allowance is taxable, whether a period qualifies, or whether ZRA has already initiated action.

Step 5: Obtain governance approval and keep the evidence

For material exposures, give the board or executive committee a short decision paper. It should set out the tax type, periods, principal tax, estimated interest, expected penalty treatment, funding source and whether ZRA has made prior contact.

This governance record helps directors make an informed decision about cash, reporting and risk. It also prevents a disclosure from becoming a finance-team exercise with no owner for the payment obligation.

Keep copies of the application, all supporting schedules, amended returns, TaxOnline confirmations, payment evidence and any Time to Pay Agreement. If the business later undergoes due diligence, those records show how management identified and addressed the issue.

When a voluntary disclosure is worth pursuing

If an enterprise has a genuine income-tax error, complete records and no ZRA action for the relevant period, it should assess the VDP promptly. Waiting for a routine audit cycle creates a real risk that ZRA will detect the issue first, which defeats a core qualifying condition.

If turnover is under the threshold relevant to your business and the issue involves turnover tax rather than corporate income tax, do not assume the analysis ends there. Turnover tax falls within the taxes listed in ZRA’s VDP guide, but eligibility still depends on the five statutory conditions and the facts of the relevant periods.

If the liability concerns VAT, customs, excise or property transfer tax, do not submit a section 91A application without confirming the route available. The current programme does not state that those taxes fall within its scope.

Tax advisory support is most useful before the first letter leaves the business. We help enterprises review tax exposures, prepare voluntary disclosure submissions, reconcile PAYE and withholding tax positions, and strengthen tax compliance controls after regularisation.

Frequently Asked Questions

Does ZRA voluntary disclosure waive all tax owed?

No. A qualifying disclosure waives penalties. Principal tax remains payable, and interest generally remains payable unless the Income Tax Act separately provides an exemption.

Is the extended voluntary disclosure programme still open?

The 2022/23 Tax Amnesty extension closed on 30 June 2023. From 1 January 2026, taxpayers with qualifying income-tax issues should assess the permanent statutory VDP under section 91A instead.

Can I use the VDP after ZRA starts an audit?

Not for a period where ZRA has already issued an audit notice, assessment, investigation or enforcement action. The disclosure must be taxpayer-initiated before ZRA detects the error.

Is there a ZRA voluntary disclosure form?

The current ZRA guide does not prescribe a form. Submit a written application to the Regional Director, Domestic Taxes Division, with the error, tax type, periods, computation and supporting documents, then file or amend returns through ZRA TaxOnline.

Zambia’s voluntary disclosure rules changed on 1 January 2026, and the consequences depend on the exact tax type, periods and ZRA correspondence on file. Speak With Our Team to review your position before ZRA identifies the issue.