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posted 5 minutes ago
Last reviewed: June 30, 2026
Withholding tax on rentals in Zambia has undergone a fundamental structural shift since 1 January 2022, yet many tenants and landlords still operate under assumptions inherited from the old 10 % regime. Under the current framework, the obligation to account for tax on rental income falls primarily on the landlord through a standalone Rental Income Tax, rather than through tenant-level withholding at source. This guide sets out the withholding tax rates applicable in Zambia for 2026, clarifies exactly who withholds and who pays, walks through ZRA e-filing steps and deadlines, and details the penalties that apply when obligations are missed.
Whether you are a corporate tenant, an individual landlord or a property management firm acting as agent, the practical workflows below will help you stay compliant.
Before reading the full guide, note the key compliance actions that apply right now:
Do you pay withholding tax on rent? The short answer for 2026: a resident landlord pays Rental Income Tax directly to ZRA; a tenant only withholds if specifically designated by the Commissioner-General or if the landlord is non-resident.
Understanding the applicable withholding tax rate in Zambia depends on whether the payment is classified as rental income subject to the standalone Rental Income Tax or as a general payment subject to standard WHT. The table below contrasts the historical position with the current regime.
| Entity / Payment Type | WHT (Historical, Pre-2022) | Current Treatment (2022–2026) |
|---|---|---|
| Tenant paying rent to a resident landlord | Tenant withheld 10 % on gross rent and remitted to ZRA. | Default: landlord pays Rental Income Tax directly. Tenant only withholds if designated by Commissioner-General (ZRA Rental Income PDF). |
| Resident landlord, annual gross rental income | 10 % final withholding tax (flat rate). | Graduated bands: 0 % on the first K12,000; 4 % on the next K788,000; 12.5 % on the excess above K800,000 (ZRA Rental Income PDF; PKF Zambia 2025 Tax Alert). |
| Non-resident landlord | 10 % WHT (or up to 20 % in certain contexts). | 20 % WHT on gross rent is the default unless a DTA prescribes a lower rate (PwC Tax Summaries; M&J Consultants). |
For resident landlords, the rental income tax is a final tax, the income is not aggregated with other income for corporate or personal income tax purposes. Non-resident withholding tax on rentals in Zambia remains a payer-level obligation and is likewise a final tax.
Prior to 1 January 2022, the taxation of rental income in Zambia operated through a simple withholding mechanism. The tenant deducted 10 % of gross rent at the point of payment and remitted it to ZRA on the landlord’s behalf. This was a final tax, meaning the landlord had no further filing obligation in respect of that rental income.
With effect from 1 January 2022, the Government introduced a standalone Rental Income Tax. Under this regime the liability shifted squarely to the landlord, who must now register with ZRA, file periodic returns, and pay the tax due on gross rental income according to graduated bands (ZRA Rental Income PDF). The tenant’s historical withholding obligation was effectively removed as the default position.
However, this does not mean tenants are entirely free of obligations. The Commissioner-General of ZRA retains the statutory power to designate any person, including a tenant or a property management company, as a withholding agent for rental income (PwC Tax Summaries, Zambia). Where such a designation is made, the designated agent must withhold the appropriate amount, remit it to ZRA, and issue a withholding tax certificate to the landlord.
Industry observers expect that ZRA will continue to rely on Commissioner-General designations for large corporate tenancies and government agencies, particularly where collection compliance has historically been low.
The question of who pays withholding tax in Zambia in the rental context depends on three factors: the residency of the landlord, any active designation by the Commissioner-General, and the type of tenancy arrangement in place.
Default position (resident landlord, no designation): The landlord registers with ZRA, computes Rental Income Tax on gross rental receipts using the graduated bands, files a return, and pays the tax directly. The tenant’s only obligation is to pay the agreed rent in full without any deduction.
Designated withholding (Commissioner-General designation): Where ZRA has formally designated the tenant, or a property management firm acting on the landlord’s behalf, as a withholding agent, the designated party must deduct the prescribed amount from each rental payment, remit it to ZRA by the 14th of the following month, and furnish a withholding tax certificate to the landlord (ZRA Withholding Taxes PDF).
Non-resident landlord: The tenant (or agent making payment) must withhold 20 % of gross rent and remit to ZRA, unless a DTA between Zambia and the landlord’s country of residence specifies a lower rate. This withholding obligation applies automatically and does not require a separate Commissioner-General designation.
Corporate tenants operating across multiple leased sites should verify their designation status directly with ZRA to avoid inadvertent non-compliance. The practical effect of an undiscovered designation is that the tenant becomes personally liable for unremitted tax, penalties and interest.
The following examples illustrate how the current Rental Income Tax bands apply to resident landlords and how the 20 % WHT applies to non-resident scenarios.
Example 1, Small residential landlord (resident)
A landlord receives K4,000 per month in gross rent from a single residential property. Annual gross rental income: K48,000.
The landlord files and pays this amount to ZRA. The tenant pays the full K4,000 monthly rent with no deduction.
Example 2, Commercial landlord with high-value portfolio (resident)
A landlord receives K120,000 per month across several commercial properties. Annual gross rental income: K1,440,000.
A Zambian company pays K50,000 monthly rent to a landlord resident in a country with no DTA with Zambia. The tenant must withhold 20 % of gross rent each month:
If a DTA is in force (for example, with the United Kingdom or South Africa), the applicable treaty rate may be lower. To claim DTA relief, the tenant must obtain a certificate of tax residence from the landlord’s home-country tax authority and retain it on file for ZRA audit purposes.
Whether you are filing as a landlord under the Rental Income Tax regime or as a designated withholding agent, ZRA’s TaxOnline portal is the primary channel for returns and payments. The step-by-step process is as follows:
Late submissions attract automatic penalties, so building the 14th-day deadline into your monthly accounting calendar is essential. For large property portfolios, early indications suggest that ZRA is increasingly cross-referencing rental tax filings with property transfer records, making accurate and timely filing more important than ever.
Where withholding does occur, either because of a Commissioner-General designation or a non-resident payment, the withholding agent must issue a withholding tax certificate to the landlord. This certificate serves as the landlord’s evidence that tax has been deducted and remitted to ZRA (ZRA Withholding Taxes PDF).
For landlords paying Rental Income Tax directly, the ZRA e-payment receipt and filed return serve as proof of compliance. Landlords should retain these alongside tenancy agreements, bank statements showing rental receipts, and any correspondence with ZRA.
Failure to comply with withholding or Rental Income Tax obligations attracts significant financial consequences. The penalty regime under the Income Tax Act, as summarised by ZRA and confirmed in the PKF Zambia 2025 Tax Alert, includes:
ZRA enforcement has intensified in recent years. Academic research from the University of Zambia highlights ongoing challenges with WHT collection in the informal rental sector (UNZA DSpace), and the likely practical effect is that ZRA will continue to expand its use of Commissioner-General designations and data-matching to improve compliance among formal-sector landlords and tenants.
The Commissioner-General’s power to designate withholding agents is discretionary, but in practice it targets scenarios where direct landlord compliance is difficult to enforce. Common situations where designation occurs or should be anticipated include:
This article was produced by Global Law Experts. For specialist advice on this topic, contact Emmanuel Manda at Musa Dudhia & Co., a member of the Global Law Experts network.
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