How to Object to a ZRA Assessment and Appeal to the Tax Appeals Tribunal in Zambia

The short answer

If the Zambia Revenue Authority (ZRA) issues an assessment you disagree with, you have 30 days from the date it was served to lodge a written objection setting out your grounds (Income Tax Act, section 108). If the Commissioner-General's written decision on that objection still leaves you aggrieved, you have 30 days from being notified of it to file a notice of appeal with the Tax Appeals Tribunal in Lusaka, with the filing fee (Tax Appeals Tribunal Rules, 2022, rule 5). The Tribunal must decide within 60 days of the end of the hearing.

None of that pauses payment. Section 77(4) makes tax under an assessment due within 30 days of service, and section 77(6) says that applies "notwithstanding that the person assessed objects to or appeals". The Commissioner-General can extend the time to pay, but only if asked.

This guide sets out each stage with the section and rule numbers, because the deadlines are short and nothing in the law obliges ZRA to remind you of them.

Why the burden is on you

Section 106 of the Income Tax Act says every assessment "shall stand good unless proved otherwise by the person assessed upon objection or appeal". ZRA does not have to justify the assessment first; you have to show it is wrong. That shapes everything below: an objection that merely says the figure is too high will fail, and an appeal that produces no documents will fail at the Tribunal, which under section 13 of the Tax Appeals Tribunal Act can dismiss a frivolous or vexatious appeal with costs against you.

So before you write anything, gather the file: the notice of assessment and the date it reached you, the return you filed, the bank statements, invoices, payroll records and contracts behind the figures in dispute, and your own computation of what you say the tax should be.

Stage 1: the objection (section 108)

Section 108 gives the person assessed the right, "within thirty days of the date of service of notice of assessment", to make "a written statement of objection to the assessment setting out the grounds of objection" to the Commissioner-General. The Commissioner-General must then give written notice of the decision.

What that means in practice:

• Count 30 calendar days from service, not from when you read it. If the notice arrived through your TaxOnline account or by post, the date of service is the date it was delivered to you or your agent.
• In writing, with grounds. Each ground should identify the figure or treatment in the assessment, what you say it should be, and the evidence. Attach the evidence.
• Ask for more time if you need it, before day 30. Proviso (i) to section 108 lets the Commissioner-General determine that an objection may be made within a longer period. If that request is refused, the proviso lets you appeal the refusal to the Tribunal without first objecting.
• Keep proof of lodging. A stamped copy, a TaxOnline acknowledgement or a dated email. If the dispute goes to the Tribunal, you will exhibit it.

The Act does not set a deadline for ZRA to decide an objection. If an amended assessment is issued as a result of your objection and you do not object to it, proviso (iv) treats that amended assessment as the Commissioner-General's written decision, which starts the appeal clock. Read every amended assessment with that in mind.

Objections are not limited to assessments. Section 114(2) lets you object to, and appeal against, a determination of the Commissioner-General "as if the determination were an assessment", so a disputed ruling on, say, whether an expense is deductible follows the same route. A matter left to the Commissioner-General's discretion, however, "shall not be questioned in any proceedings" (section 114(1)(a)).

Stage 2: pay, or ask for time to pay (section 77)

Section 77(4): tax under an assessment "shall be due and payable by the person assessed within thirty days of the service of notice of assessment". Section 77(6): that rule "shall have effect notwithstanding that the person assessed objects to or appeals against that assessment". This is the Zambian form of "pay now, argue later".

Two practical points:

• Section 77(5) gives the Commissioner-General discretion to extend the time for payment. Ask for it in writing, with the objection, and ask specifically for the disputed portion to be held over pending the decision. Pay the undisputed portion on time. The Act does not oblige ZRA to agree, and an unpaid assessed amount attracts the late-payment penalties and interest in section 78 while the dispute runs.
• If you win, section 113 requires the Commissioner-General to make all assessments and adjustments necessary to give effect to the determination, and any tax paid in excess is refunded under section 87.

For a business, the usual approach is to pay what you accept, apply for an extension on the balance, and keep paying the current year's provisional tax on its normal dates (quarterly payment dates and the tax guide).

Stage 3: appeal to the Tax Appeals Tribunal

The Tax Appeals Tribunal was created by the Tax Appeals Tribunal Act, 2015 (which renamed the former Revenue Appeals Tribunal). Section 5 gives it jurisdiction over appeals from the Commissioner-General's decisions under the Customs and Excise Act, the Income Tax Act, the Property Transfer Tax Act, the Value Added Tax Act and other tax legislation. It is made up of three legal practitioners of at least ten years' standing, two chartered accountants certified by the Zambia Institute of Chartered Accountants and two members from the business community (section 4); three members, including the Chairperson or Vice-Chairperson, sit on each appeal (section 8(3)). A hearing before it is a judicial proceeding (section 8(6)).

The procedure is in the Tax Appeals Tribunal Rules, 2022 (Statutory Instrument No. 37 of 2022). The steps:

1. File the notice of appeal within 30 days of being notified of the decision (rule 5(1), matching section 109(1) of the Income Tax Act). It is in Form I, with an affidavit in Form II exhibiting a copy of the decision and every relevant document, and it is filed at the Principal Registry in Lusaka or a regional registry designated by Gazette notice (rule 3). File at least ten copies (rule 40).
2. Pay the filing fee. Rule 5 makes the fee a condition of filing, and rule 38(2) makes it non-refundable. The Second Schedule sets the notice-of-appeal fee at 10,000 fee units for a large taxpayer, 5,000 for a medium taxpayer and 1,666.66 for a small taxpayer, converted at the fee-unit value fixed under the Fees and Fines Act. Check the current conversion with the Registry before you pay.
3. Serve ZRA and file an affidavit of service (rule 6). The appeal is not properly before the Tribunal until ZRA has been served.
4. ZRA answers within 14 days with an affidavit in opposition and the documents behind its decision (rule 9(1)); you may file an affidavit in reply within 7 days of being served (rule 9(3)).
5. Scheduling conference. Within 14 days of the time for ZRA's affidavit, the Registrar summons both parties to fix witnesses, witness statements, lists of authorities and a hearing date (rule 10). Miss two consecutive scheduling conferences without justifiable cause and the Registrar may dismiss the appeal (rule 10(3)).
6. Hearing. You get at least 14 days' notice (rule 12). Proceedings are public unless the Tribunal directs otherwise on application (rule 13), and section 112 of the Income Tax Act lets a taxpayer require income-tax proceedings to be held in private. You may appear in person or through a legal practitioner at your own expense (Act, section 8(8)). Adjournments are granted only "in compelling and exceptional circumstances" and can carry a hearing fee (rule 15).
7. Decision within 60 days of the conclusion of the hearing (Act, section 10), communicated by the Registrar within 7 days (section 12). The Tribunal may award costs as it considers just (section 11).

At any stage before the decision, you and ZRA can settle. Section 110(2) of the Income Tax Act requires the agreement to be put in writing and signed, after which the Tribunal makes an order in its terms (rule 28 provides for consent orders).

Missed a deadline?

• Objection late. Ask the Commissioner-General under proviso (i) to section 108 to allow a longer period, with the reason. If refused, the refusal itself can be appealed to the Tribunal.
• Appeal late. Rule 7 lets you apply to the Registrar for an extension of the 30 days; the application carries its own fee (Second Schedule) and the Registrar's power to extend any period is capped at seven days (rule 39(5)). Section 109(2) of the Income Tax Act separately allows the Tribunal to extend the appeal period where "absence from the Republic, sickness or other reasonable cause" prevented a timely notice and there was no unreasonable delay. An application for an extension should be filed with the notice of appeal, not instead of it.

Neither route is generous. Treat day 30 as the deadline and the extensions as a safety net you hope never to need.

After the Tribunal

Section 15 of the Tax Appeals Tribunal Act gives either party a further appeal from the Tribunal's decision on a question of law or of mixed law and fact, but not on a question of fact alone. Which superior court hears that appeal has shifted with the restructuring of Zambia's courts since the Act was passed, so take legal advice at that stage rather than relying on the wording of either Act.

A worked timeline

Assume a notice of assessment for an additional K40,000 is served on 2 March.

Mistakes that lose otherwise good cases

• Objecting by phone or at the counter without a written statement of grounds. Section 108 requires a written statement setting out the grounds; nothing else stops the clock.
• Treating an amended assessment as "under review". Under proviso (iv) to section 108, an amended assessment issued after your objection is the decision. If you still disagree, object to it or appeal within 30 days.
• Assuming the objection suspends payment. It does not (section 77(6)). Apply for an extension and pay the undisputed part.
• Filing the appeal without the fee, the affidavit or the copies. Rule 5 makes the fee a condition of filing; rules 5(2) and 40 require the affidavit exhibiting the decision and ten copies.
• Forgetting to serve ZRA. Rule 6 requires service and an affidavit of service.
• Skipping the scheduling conference. Two consecutive absences let the Registrar dismiss the appeal.
• Arriving with assertions instead of documents. Section 106 puts the burden on you; the Tribunal decides on evidence, and section 13 lets it dismiss a frivolous appeal with costs.

Who this affects most

• Small businesses on turnover tax that receive an estimated assessment after a missed return. The objection route is the same; so is the 30-day payment rule (turnover tax filing guide).
• Employers assessed for under-deducted PAYE or late NAPSA and NHIMA contributions, where the dispute is often about which payments were taxable (employer payroll obligations).
• Employees with a second income or a terminal benefit who filed a return and received an assessment they did not expect (understanding your payslip, redundancy and terminal benefits).
• New registrants whose TPIN was linked to the wrong tax types and who are assessed for a tax they were never liable for (how to get a TPIN, how to register a business).

Frequently asked questions

Does ZRA have a deadline to decide my objection? The Income Tax Act sets none. It requires a written decision but no time limit. If ZRA issues an amended assessment instead of a letter, that is the decision.

Do I have to pay before I can object or appeal? Objecting and appealing are not conditional on payment, but the tax remains due 30 days after the assessment was served (section 77(4) and (6)). Apply to the Commissioner-General for an extension on the disputed amount.

How much does the Tribunal cost? The filing fee depends on your taxpayer category: 10,000, 5,000 or 1,666.66 fee units for large, medium and small taxpayers. It is non-refundable. Legal representation is at your own expense, and the Tribunal may award costs either way.

Can I represent myself? Yes. Section 8(8) of the Tax Appeals Tribunal Act allows a party to appear in person or through a legal practitioner. For anything above a small amount, representation is worth the cost: the procedure is affidavit-based and the burden of proof is yours.

Can the Tribunal increase my assessment? It makes "such order in relation to the assessment under appeal as is in accordance with this Act" (section 110(1)). Appeals are not risk-free; a weak appeal can end with costs.

My dispute is about VAT or customs duty, not income tax. The Tribunal hears those too (Tax Appeals Tribunal Act, section 5), and the Rules apply to all of them. The objection stage and its deadline, however, are set by each Act separately; check the VAT Act or Customs and Excise Act provision that applies to you.

Sources: Income Tax Act, Chapter 323, sections 77, 87, 106 to 114; Tax Appeals Tribunal Act, No. 1 of 2015, sections 4, 5, 7, 8, 10 to 13 and 15; Tax Appeals Tribunal Rules, 2022 (Statutory Instrument No. 37 of 2022), rules 3, 5 to 13, 15, 28, 38 to 40 and the Second Schedule. Statutory text checked 24 October 2026. General information, not legal or tax advice.