international tax services doing business in zambia - pwc · agenda page 1 zambia at a glance 1 2...

International Tax Services

Doing business in Zambia

March 2013

Agenda

Page

1 Zambia at a glance 1

2 Zambia’s economic outlook 5

3 Government policies and budget 18

4 Key growth drivers 22

5 Tax and investment incentives 28

6 Practical considerations of investing in Zambia 37

7 South African investment into Zambia 40

8 Hot Topics 42

PwC

March 2013

Zambia at a glance

1

Section 1

Doing business in Zambia •

PwC

March 2013

Background on Zambia General Facts

• Population: 13.5 million (SA: 50.5m) (World Bank)

• Area: 752,614 square km SA: 1,219,912 km2

• Major languages: English (official, used for business), Nyanja, Bemba

• Centrally located with eight neighbouring countries

• Currency: Kwacha

This was rebased on 1 January 2013

1 000 Old Kwacha (ZMK) = 1 New Kwacha (ZMW)

1 ZAR: 0.58678 ZMW (rate utilised per Oanda.com, 12 March 2013)

2


Section 1 – Zambia at a glance

REPUBLIC OF ZAMBIA

PwC

March 2013

Background on Zambia General Facts

• Capital city: Lusaka

• Other notable cities: Kitwe, Ndola, Kabwe, Chingola, Mufulira, Luanshya, Livingstone

Of these, most are in the Copperbelt province

• President Michael Chilufya Sata was elected in 2011

• Politically stable

3



President Michael Sata

(Source: Times of Zambia)

• Major trade agreements:

- Africa Growth Opportunity Act

- Southern African Development Community

- Common Market for Eastern and Southern Africa

(Source: Wikipedia)

PwC

March 2013

Background on Zambia Economic Facts

• Well endowed with minerals – much of them unexploited

− World’s 7 th largest producer of copper

− World’s 2 nd largest producer of cobalt

4



Nkana mine (Source: Wikipedia)

• Has seen a decade of strong growth, averaging 6.7% since 2008

• Has a track record of fiscal discipline with deficits averaging 3.1% of GDP between 2007 and 2011

• External debt ratios generally low and liquidity ratios high

• Inflation has been in single digits for the last 3 years

• No exchange controls over last 20 years

//upload.wikimedia.org/wikipedia/commons/9/92/ZM-Nkana-headgear-Kitwe.jpg

PwC

March 2013

Zambia’s economic outlook

5

Section 2


Africa’s time …....

7 of the top 10 fastest growing economies between 2001 and 2010 were African countries and are forecast to be in top 10 fastest growing between 2011 and 2015.

Ghana Avg GDP growth

p.a. 2011 - 2015

Population

(m) 2010

7.0% 24.4

Nigeria Avg GDP growth

p.a. 2011 - 2015

Population

(m) 2010

6.8% 158.4

Congo Avg GDP growth

p.a. 2011 -2015

Population

(m) 2010

7.0% 4.3

Ethiopia Avg GDP growth

p.a. 2011 - 2015

Populatio

n (m) 2010

8.1% 82.7

Zambia Avg GDP growth

p.a. 2011 - 2015

Populatio

n (m) 2010

6.9% 12.9

Mozambique Avg GDP growth

p.a. 2011 - 2015

Populatio

n (m) 2010

7.7% 23.4

(Source: Economist, IMF, UN – Department of Economic and Social Affairs)

Avg GDP growth

p.a. 2011 - 2015

Populatio

n (m) 2010

7.2% 44.8

Tanzania

PwC

March 2013

Economic outlook

7


Section 2 – Zambia’s economic outlook

Bank Lending rates

• 2012 Interest rate 9% prime

• Bank lending rates down from 24% in 2011 to 16% in 2012/13

• SNDP average target of less than 20% for the period 2011 to 2015

• Bank lending rates capped at 18.25% in Jan 2013

Inflation

• 2012 Inflation was 7.3% 2013 Inflation projected to close at 6.5%

• SNDP average inflation targeted at less than 10% for the period 2011 to 2015

Other

Import cover

• Targeted at 4 months cover

Government borrowing

• To be limited to 1.5% of GDP

GDP

• 2012 GDP was 6.9% 2013 GDP projected to close at 7.1%

• SNDP average GDP growth target is over 6% for the period 2011 to 2015

• Fitch forecast GDP growth expected to be between 7.7% and 7.9% for 2013-2014

PwC

March 2013

GDP growth rates

-1

0

1

2

3

4

5

6

7

8

2008 2009 2010 2011 2012* 2013*

GD

P g

ro

wth

%

Zambia

Africa

Global

8



PwC

March 2013

Economic outlook

• Global demand for raw materials and commodities from the BRIC’s and other emerging economies on the increase after the 2008/9 Global Financial Crisis

• Copper production expected to grow from 890,000mt to 1.5m metric tonnes by 2015

• Significant increase also expected in the production of other minerals manganese, iron ore, coal, uranium, and gold

• Greater diversification – move away from copper dependency – to agriculture, energy, infrastructure and manufacturing

• More private sector participation through the PPP initiatives

• Significant increase in foreign direct investment (FDI)

• SNDP focus on mining, energy, agriculture & manufacturing sectors

9



PwC

March 2013

Economic outlook

• In July 2011 the World Bank classified Zambia as:

− one of the top 5 destinations for FDI in Sub-Saharan Africa; and

− Middle Income Country from an LDC

• In 2012, Forbes magazine placed Zambia as amongst Africa’s 5 best investment destinations

• Successful Eurobond issue of US $750m in 2012 – oversubscribed by 24 times

• Credit lending increased by 24% y-o-y in 2012

• Non performing loans (commercial) reduced from 16% in 2010 to 8.6% in 2012

• February 2013, Zambia achieved a B+ credit rating from Fitch

• Stable political and social environment

10



PwC

March 2013

Economic outlook Doing Business 2013

• The World Bank runs a survey each year called “Doing Business”. This survey ranks each of 185 countries in how easy or difficult it is for a local entrepreneur to open and run a small to medium-size business when complying with all the relevant regulations.

• These rankings do not tell the whole story, but give an indication of whether the government has created a regulatory environment conductive to operating a business or not. (Ranking being 1 the best, to 185 being the worst of the countries analysed).

11



Zambia Mozambique SA

Ranking in 2013 94 146 39

Ranking in 2012 90 139 41

PwC

March 2013


12



Topic Rankings Zambia

2013

Mozambique

2013

SA

2013

Starting a business 74 96 53

Dealing with construction permits 151 135 39

Getting electricity 151 174 150

Registering property 96 155 79

Getting credit 12 129 1

Protecting investors 82 49 10

Paying taxes 47 105 32

Trading across borders 156 134 115

Enforcing contracts 89 132 82

Resolving insolvency and

employing workers

99 147 84

TOTAL RANKING 94 146 39

PwC

March 2013


13



World Bank. 2013. Doing Business 2013: Smarter Regulations for Small and Medium-Size Enterprises. Washington, DC: World Bank Group. DOI: 10.1596/978-0-8213-9615-5. License: Creative Commons Attribution CC BY 3.0

PwC

March 2013

FDI Flows into Zambia

14



Investing in Zambia Source: World Investment Report 2012

616

1324

939

695

1729

1982

0

500

1000

1500

2000

2500

2006 2007 2008 2009 2010 2011

US $ (million)

PPP

PwC

March 2013

FDI trend breakdown

15



2010 FDI flow by sector

Agriculture

Mining

manufacturing

Wholesale and retail trade

Tourism

Transport &Communication

Construction

Real Estates

Bank and Non Bank Fin Insts

Financial & Insurance

Accomodation & Food

Other

PwC

March 2013

FDI trends in Zambia Sector analysis

16



Sector Number of projects (2007-2012)

Manufacturing 403

Service 129

Tourism 119

Agriculture 108

Mining 97

Construction 93

Transport 81

Real Estate 80

Health 24

ICT 23

Energy 14

Education 11

Finance 07

PwC

March 2013

FDI Flows Distribution of flows among African Economies

17



Source: United Nations Conference on Trade And Development: World Investment Report 2012. http://unctad.org/en/PublicationsLibrary/wir2012_embargoed_en.pdf

Regional trends: Africa • Zambia ranks in the second tier of

inflow FDI measured of between $2 to $2.9 billion.

PwC

March 2013

Government policies and budget

18

Section 3


PwC

March 2013

Government focus

2012 Election pledge –

“To make Zambia a better place for all”

- To achieve a more equitable distribution of wealth derived from mineral resources

- To put more money in peoples pockets

2013 Budget

“Delivering Inclusive development and social justice”

- Employment creation

- Reduce the cost of doing business

- Improve infrastructure

- Diversification strategy

- Improve transparency, reduce corruption

19


Section 3 – Government policies and budget

PwC

March 2013

20



2013 budget Key measures

Creation of 200,000 jobs

Improve road, rail and energy infrastructure - 91% of the proceeds from US $750M Eurobond issue to be allocated to this

Launching the Link Zambia 8000 project

Farmer input support program extended to crops other than maize

Zambia to co-host 2013 UN World Tourism Organisation Conference

PwC

March 2013

21



Key measures 2012 and 2013

• Increased mineral royalty rate from 3% to 6%

• Increase in minimum wages by 67%

• Financial measures

reduction in statutory liquid ratios

SI 33 all domestic transactions in Kwacha

introduction of a policy rate to provide reference rate followed by interest rate caps for commercial banks to reduce cost of borrowing

January 2013 –rebasing of Kwacha

Increase Tier 1 capital requirements for foreign banks from US $10m to US $100m

PwC

March 2013

Key growth drivers

22

Section 4


PwC

March 2013

Key growth drivers

Mining and quarrying

Copper production in 2011 was 816,000mt (amount achieved in the early 1970’s – 720,000mt) 2012 estimated at 890,000mt

Sector will continue to be the major contributor to Zambia’s economic growth

23


Section 4 – Key growth drivers

Focus will be on:

increased exploration projects

sustainable production and management of mineral resources

increased productivity and better Govt. control over operations of MNC’s

focus on other ores; manganese, iron ore, uranium, nickel, coal, gold

value-add in country key priority

PwC

March 2013

Key growth drivers

Energy

GRZ has lined up a number of programs to foster growth in this sector, including:

Rural Electrification

Development of Strategic Petroleum Reserves

Renewable and Alternative Energy Development

Building of new 1600MW hydro

Thermal power coming on stream – investment of US $1.4bn

Exploration permits granted for oil prospecting

24



PwC

March 2013

Key growth drivers

• Favourable tax regime –corporate tax rate of 10%, additional allowances (farm improvement and farm works allowances of 100%), ZDA incentives

• Significant activity in terms of commercial developments in tobacco, cotton, wheat, maize, soya beans, fisheries and poultry

• Zambia has the highest underground water content of any country in Sub Saharan Africa

25



Agriculture & Livestock

• GRZ’s strategic programs to include:

Irrigation Development sub program

Farm Block Development

Fisheries and livestock development (restocking of livestock in other parts of the country)

Better support to small scale famers through various programmes from cooperating partners

Source: Zambia Weekly Week 7, Volume 4, Issue 6, 15 February

PwC

March 2013

Key growth drivers

26



Manufacturing and construction

• Key objectives include:

expansion of industrial base

increase in value addition

facilitation of private sector development

• Growth in this sector will be driven mainly by the creation of Multi Facility Economic Zones (“MFEZ”) and Industrial Parks

• Operational MFEZ areas include:

Lusaka East – light industries

Lumwana – light and heavy industries

Chambeshi – light and heavy industries (developer - China Non Ferrous Metals)

Lusaka South – under PPP framework

Sub-Saharan Gemstone Exchange Industrial Park, Ndola

Roma Industrial Park

PwC

March 2013

Projects per sector

27



Sector Companies investing or exploring investment

Mining • Kalimbila Mine (copper) – Trident, New Sentinnel and Reginald

• Mulyashi Mine (copper) – CNMC • Barricks Chimiwungo pit • Exploration – VALE, Anglo Exploration, Rio Tinto, African

Rainbow.

Energy Energy development and distribution projects: • Itezhi Tezhi project • Kafue Gorge Lower power station • North Bank power station

Agriculture • Alliance One • JTI • Zambia Tobacco Leaf • Cargill • Dunavants • Mpongwe • Zambia Sugar

PwC

March 2013

Tax and investment incentives

28

Section 5


PwC

March 2013

Tax regime -general

29


Section 5 – Tax and investment incentives

* With the exception of minerals, electricity, services and cotton lint exported without an export permit from Minister of Commerce. ** Subject to application of a tax treaty.

General tax rates Rate (2013)

Corporate tax rate 35%

Telecommunication companies • income less than ZMK 250,000, apx. US$ 50,000 • income exceeds ZMW 250,000

35% 40%

Listings New listings on LuSE * New listings on LuSE > 33% shares taken up by Zambians *

2% discount 7% discount

Withholding tax ** • Dividends • Interest payments • Royalties • Management fees

15% 15% 20% 20%

Carry forward of Trading losses • Non-mining companies • Hydro and thermo power generation companies

5 years 10 years

PwC

March 2013

Zambian tax Specific tax rates for Mining

30



Mining companies Rate (2013)

Corporate rate 30%

Variable profit tax (applicable when taxable income from mining operations exceeds 8% of the gross sales)

Up to 15%

Withholding tax * • Dividends • Interest payments • Royalties • Management fees

0% 15% 20% 20%

Mineral royalty 6%

Property Transfer Tax (transfer of mineral rights) 10%

Carry forward of trading losses • Konkola Copper Mines Plc • From mining operations • Prospecting and exploration companies

20 years 10 years 5 years

* Subject to application of a tax treaty.

PwC

March 2013

Zambian tax Specific tax rates for Farming

31



Farming business Rate (2013)

Corporate rate 10%

Export of non-traditional products 15%

Capital deduction • Farming improvement / Farm Works allowance

100%

Implements, machinery and plant: • Used for farming, manufacturing, tourism and leasing • Carry forward of Trading tax losses

50% 5 years

PwC

March 2013

Investment incentives ZDA incentives – Fiscal incentives

32



Zambia Development Agency (ZDA)

The ZDA offers fiscal and non-fiscal incentives to investors that invest at least US$500,000 in a priority sector/product

Fiscal incentives

• 0% tax rate on dividends for the first 5 years

• 0% tax on profits for the first 5 years

• For years 6 to 8, only 50% of profits are taxable

• Years 9 & 10, only 75 % of profits are taxable

• 0% customs duty rate on raw materials, capital goods, machinery

• Deferment of import VAT on imported machinery and equipment including trucks and specialised motor vehicles

• Priority sectors include: horticulture, food processing, manufacturing of engineering products involving metals, processing beverages.

PwC

March 2013

Investment incentives ZDA incentives – Non fiscal incentives

33



Non fiscal incentives

• Investors, who invest at least US $ 250,000, are entitled to an Investor Permit and up to 5 employment permits for expatriates

Free facilitation/ assistance with the following:

• Land acquisition

• Obtaining facilities and amenities required for their investment e.g. water, electric power, communication services

• Regularizing immigration status

• Acquiring other licenses required to operate the business

• Access to any care assistance

PwC

March 2013

Countries with a DTA with Zambia:

DTA’s with Zambia


34


• Canada

• China

• Denmark

• Finland

• France

• Germany

• India

• Ireland

• Italy

• Japan

• Kenya

• Mauritius

• Netherlands

• Norway

• South Africa

• Sweden

• Switzerland

• Tanzania

• Uganda

• United Kingdom

PwC

March 2013

Zambian tax treaty network in Africa


35


5 DTA in force

Summary

Without DTA

Zambia

Libreville

Kananga

Ndola

Nacala

Dar es Salaam

Zanzibar

Mombasa

Beira

Kalemie

Antananarivo

Maputo

Lusaka

Bulawayo

Harare

Gaborone

Johannesburg

Durban

Port Elizabeth

Maseru

Mbabane

Cape Town

Luderitz

Walvis Bay

Windhoek

Namibe

Menongue

Lobito

Malanje

Lilongwe

Mbeya

Lake Tanganyika

Luanda

Kinshasa

Brazzaville

Pointe-Noire

Toliara

Pretoria

Agadez

Zinder

Faya-Largeau

N' Djamena Maiduguri

Kano

Abuja

Khartoum

Al Fashir

Asmara

Addis

Ababa

Port Sudan

Malabo

Yaounde

Bangui

Djibouti

Berbera

Mogadishu

Kisangani

Bujumbura

Nairobi

Kampala

Kigali

Bechar

Tripoli

Al Jawf

Oran

Algiers Tunis

Cairo

Aswan

Constantine Rabat

Marrakech

Casablanca

Laâyoune

Tombouctou Nema

Nouakchott

Tamanrasset

Niamey Bamako

Alexandria

Banghazi

Abidjan

Accra

Loma

Porto-Novo

Ouagadougou

Lagos

Dakar

Monrovia

Freetown

Banjul

Conakry

Bissau

TANZANIA

BURUNDI

EQUATORIAL GUINEA

ANGOLA

REPUBLIC

OF THE

CONGO

MALAWI

ZAMBIA MOZAMBIQUE

MADAGASCAR

ZIMBABWE

BOTSWANA

SWAZILAND

LESOTHO

SOUTH AFRICA

NAMIBIA

ANGOLA

NIGER

CHAD

SUDAN

ETHIOPIA

DJIBOUTI

ERITREA

UGANDA

SOMALIA

KENYA

DEMOCRATIC

REPUBLIC

OF THE CONGO

(ZAIRE)

CENTRAL

AFRICAN

REPUBLIC

RWANDA GABON

NIGERIA

CAMEROON

TUNISIA

MOROCCO

WESTERN SAHARA

ALGERIA

MALI

LIBYA EGYPT

BENIN

TOGO CÔTE

D’IVOIRE

BURKINA FASO GUINEA

SENEGAL

GHANA

LIBERIA

MAURITANIA

SIERRA LEONE

THE GAMBIA

GUINEA BISSAU

Lake

Nyasa

Lake

Victoria

Mediterranean Sea

Red Sea

Indian Ocean

Indian Ocean

Atlantic Ocean

SOUTH

SUDAN

MAURITIUS

Port

Louis

Juba

Wau

COMORES

MAYOTTE

CAPE VERDE

Common points of entry into the

African continent

PwC

March 2013

Double Tax Agreements

36



Recipient Dividend WHT

Interest WHT

Royalty WHT

Management & consultancy

fees WHT

Mauritius 5/15 % 10% 5% 0%

South Africa 15% 15% 20% 20%

South Africa:

• The SA – Zambia treaty entered into force on 1 April 1953

• Treaty terms can be unclear and do not always provide relief

• Relief may be available for interest and royalties paid

Mauritius:

• The Mauritius – Zambia treaty entered into force on 4 June 2012

• Management & consultancy fee of 0% is dependent on the interpretation of the treaty terms

PwC

March 2013

Practical considerations of investing in Zambia

37

Section 6


PwC

March 2013

Practical considerations of investing

Registering a Business

• Business entities in Zambia must be registered / established in line with the requirements of the Companies Act 1994, as amended

• Generally most businesses register and operate through either:

A private company limited by shares; or

A branch of a foreign company

• Consider:

Minimum share capital

Director’s residence

38


Section 6 – Practical considerations of investing in Zambia

PwC

March 2013

Registering a business in Zambia

Other considerations

Other registrations:

Before beginning to trade, the entity will be required to register with the Zambia Revenue Authority (ZRA) to obtain:

• Tax Payer Identification Number (TPIN); Company income tax number; VAT and PAYE

Registration also required with the National Pension Scheme Authority and the Workers Compensation Fund Control Board

Immigration:

An individual entering Zambia for business purposes would also require the correct permit

Opening a Business Account:

This can be a complex process with detailed information requirements

39


Section 6 – Practical considerations of investing in Zambia

PwC

March 2013

South African investment into Zambia

40

Section 7


PwC

March 2013

Considerations for SA investment into Zambia Tax considerations

• Tax residency / effective management

• High tax CFC’s exempt

• Permanent Establishment

• Controlled Foreign Company (CFC) legislation

• Generally HTE or FBE exempt

• Foreign dividends

• Section 10B – exempt or 15%

• Treaty exemption on interest - SARS ruling Nov 2012

• Tax credits

• Rebate or deduction

• Via Headquarter Company or Mauritius

41


Section 7 – South African investment into Zambia

Investment

PwC

March 2013

Hot Topics

42

Section 8


PwC

March 2013

Recent - Current issues

• Approach to policy making under new administration is less clear and appears to be haphazard and abrupt

• February 2013 – Bank of Zambia Bill – Introduction of Foreign exchange Controls?

• Proposed Amendments to Companies Act could –

- Lead to restrictions in foreign owned firms

- Curb their right to borrow funds locally

• ZRA under pressure to increase collections

• Recent spate of reports on multinational tax planning exercise have an impact

• Development of a transfer pricing unit

• Assistance from Norway and UK with tax audits and investigations

43


Section 8 – Hot Topics

PwC

March 2013

Bank of Zambia Bill Risk of introduction of foreign exchange controls

• Risk of foreign exchange controls being introduced

• Bill introduced in February 2013, indicating:

• The Bank of Zambia will regulate and monitor operation of foreign exchange system. Including:

• Foreign exchange inflows and outflows

• Imports and exports of goods

• International transactions and services

• International transfers to and from non-residents

• Profits or dividends received in respect of investments abroad

• Borrowing and trade credit for non-residents

• Investment of equity and debt securities from abroad

• Receipt of principal and interest on loans to non-residents

• International money transfers into and out of Zambia

44



PwC

March 2013

Bank of Zambia Bill

• The Bank will also prescribe the maximum rate of interest and other charges that financial service providers may impose on banking transactions

• Penalties of about 540,000,000 Kwacha (USD about 10,8 million) / imprisonment

45



PwC

March 2013

Statutory Instruments SI 33 and 78

Restriction on use of foreign currency

• A company or individual cannot quote, demand, pay or receive foreign currency as legal tender for a domestic transaction

• Cannot engage in any pricing mechanism to avoid this or hedge against a foreign currency

• Domestic transaction definition:

46



Buying or selling offering to buy or sell goods or services between persons within the Republic

PwC

March 2013

Challenges

• Legislation outdated – not consolidated since 1990’s

• Generic and does not cater for modern day business – therefore need to exercise much judgement and discretion

• Commissioner General has significant discretionary powers

• Only government printers allowed to distribute legislation

• Difficult to obtain copies of old amendments and SIs

• Need to approach Ministry of Legal Affairs and Justice to determine intent of certain provisions

• Self assessment system – but no statutory limit for confirmation of assessment – creates uncertainty

• Lack of resources at ZRA

• No provisions for specific advanced clearings

• Advanced clearings not always binding

47



PwC

March 2013

Importance of tax compliance and social impressions Companies in the media

48



Tax avoidance

• Recent companies in the news for tax avoidance have included Google, Amazon and Starbucks. This has resulted in global publicity when looking at multi-national organisations in the light of tax evasion.

• Companies have been tried in the media

• Large amounts of money involved

• Tax structuring and planning versus tax avoidance. Tax structuring called into question, especially where there is no substance behind the transactions taking place.

• Tax treaties may, in practice, be stretched by local jurisdictions in order to prevent low tax concessions. (E.g. the definition of “royalties”.)

• A UK organisation called ActionAid is leading a protest against “legalised” tax avoidance methods that international companies are using through structuring, utilisation of tax treaties and tax haven jurisdictions.

PwC

March 2013

Importance of tax and social input Zambian tax news

49



PwC

March 2013

Doing Business in Zambia

50



Questions &

Answers ?

Jyoti Mistry Partner – Tax Services T: +260 (211) 256471/2 Ext 4023 M: +260 977 740641 E: [email protected]

Elandre Brandt Partner – International Taxation T: +27 11 797 5822 M: +27 83 326 7933 E: [email protected]

Key Contacts

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presentation.

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