ZRA Headquarters
ZRA Headquarters

By Kalima Nkonde

The Zambian government’s intention to replace VAT with sales tax may be a well-intentioned decision and done in good faith. However, the majority of tax and financial experts agree that the planned change from VAT to sales tax is a leap in the dark which comes with immense risks. It is generally agreed by experts that there are less costly options that Government could have explored.

This article touches on some practical problems that are awaiting ZRA, the Private sector, the economy at large and the Zambian consumer. It also suggests alternatives which are less disruptive to the proposed one and also calls for some delay, and serious introspection before sales tax is implemented.

The Zambian Government wants to switch over back to sales tax because according to the finance Minister’s budget speech: “VAT works better when you have an economy that has a strong manufacturing base. But we don’t have it! We are in constant refund and it cannot work now. We have to grow the manufacturing base because that is the sector that needs that support of a VAT refund. Right now, VAT is a subsidy and we are in austerity – we can’t afford subsidies. It is as simple as that. So, 1st April sales tax comes into play”.

The VAT system was introduced 23 years ago by the MMD government on 1st July 1995 to replace sales tax. The VAT system had served various administrations since then very well, until recently, it appears. Some of its major advantages include the following: the fact that it is invoiced based, it is therefore not a complex tax and makes it easier to collect tax, it is also a fairer tax as it avoids levying tax on tax, and it has potential to promote exports as well as the domestic manufacturing industry. VAT also provides for a wider tax base.

The above advantages are still very compelling and therefore it very curious that Zambia wants to switch over purely due to low manufacturing base and excessive refunds. It is crucial that before the government implements the new system, some of the costs and the disruptions that will be caused by the changeover are considered.

The costs, disruptions and economic impact of VAT abolishment

The implementation of sales tax comes with immense risks to the Zambia revenue authority as an institution. In addition, there are risks of increased cost of doing business, increased cost of living for Zambian consumers and general inflation, increased unemployment, may affect foreign investor sentiment and generally dampen the economic growth and delay Zambia’s economic recovery. One hope that all these facts and risks were considered and some sensitivity analysis done when the decision was made.

First and foremost, there will be need to set up a new administrative regime by Zambia Revenue authority for sales tax which will be difficult and costly as Zambia does not have the experts on sales tax. ZRA staff simply does not have the institutional memory of the sales tax regime nor is there a ready benchmark in the region to use. The issues of who is to pay the tax, which goods and service to charge sales tax on, what will the rate be, which goods will be exempt etc. will need to be figured out within five months

Secondly, there is the issue of accounting systems. Vat is an established tax and Zambia revenue Authority has accounting software which will need to be replaced with a Sales tax system. The new software could cost as much as $25million and the old VAT system will have to be thrown in the dust bin. In addition, the private sector will also have to install new accounting systems to account for VAT. They will require new software to change to the new sales tax systems and this will cost them money.

The negative impact on employment both at ZRA and the private sector should not be underestimated. ZRA employees has a large number of staff handling the VAT tax regime and these will not certainly be needed considering that activities like vat audits for refunds will not be required and so these employees will have to be retrenched. The private sector on the other hand will have to retrench some of its staff for variously reasons including the increased cost of business that sales tax will entail. Employers will consider cutting costs and employees will have to be the first target. Job losses should not be ruled out as a result of Sales tax.

There will be need to train staff at ZRA and in private sector on the operation of the new sales tax system and there are simply no expertise on the market who understands the sales tax system as it was discarded twenty three years ago.

The issue of inflation and consequently increased interest rates should not be underestimated. There is no doubt that Sales tax will increase the cost of doing business in Zambia especially as it will result in tax on tax as as all business inputs will not be recoverable and businesses will have to increase their prices and this will be contribute to increased inflation.

The Sales tax Bill has proposed a 9% Local Sales Tax and 16 % on Imports which will replace the 16% Value-Added Tax currently used on 1st July. In the past under VAT consumers used to pay 16% regardless of the value chain. Under the Sales tax regime, the longer the value chain, the higher the tax paid.
In order to put the impact on sales tax on the Zambian consumer/ voter, here is a scenario. Under the sales tax regime, if a Zambian manufacturer imports raw materials he will pay 16%, on selling to a wholesaler, 9% local sales tax will be levied, when the wholesaler sales to a retailer, 9% will be levied and when a retailer finally sales to the consumer, 9% will be charged. This means that the Zambian final consumer- the farmer, villagers, informal sector worker, they will be paying 41% tax instead of 16 % VAT. In the case of certain Zambians workers who are paying Pay and as you earn (PAYE) at the top rate of 35%, the total effective tax on their income would be 76% without taking into account all sorts of levies. The sales tax is not a smart tax to introduce from the social, economic and political view, especially when a general election is on a horizon

Zambia will be the only country in SADC and possibly COMESA region to have a sales tax system and this may influence foreign investors in their decision to locate their companies. The country will be less competitive as a destination for foreign investors in comparison to our neighbours.

There is no question that the current VAT system has been abused by the private sector especially the multinational companies and excessive refunds have been made by ZRA as pointed out by the Commissioner General, Kinglsey Chanda sometime ago.

“I wish to inform the nation that our vigilant audit teams discovered some fraudulent refund claims. This discovery prompted us to take a more cautious approach when paying refunds,” he said

In November, 2017 according to ZRA Commissioner General Kingsley Chanda, Zambia Revenue Authority (ZRA) paid out over K4 billion in values added tax (VAT) refunds to the mines and other sectors in six months. Mining companies were paid 76% of the amount, while the remainder paid to other sectors of the economy. It is estimated by some experts that the Zambian Government pays over a billion US dollars in terms of refunds per year with the mining industry getting approximately US$700million and the rest get $300million.

Options to VAT abolishment

The analysis of the problems that Zambia faces with VAT administration reveals that the bulk of refunds goes to the Mines, and two, ZRA has cash flow problems in making refunds and three, there is widespread fraud in VAT refunds claims. It follows, therefore, that these are the problems that should be addressed rather than switching to the risky sales tax which may result in negative effects on the economy may even result in less tax collections. Sales tax may do more harm than good to the overall economy.

First and foremost, the government should revise the VAT Act. The act should exempt all traditional exports like copper, cotton and tobacco. The main rationale behind the current legislation of Zero rating exports is to promote exports by making them competitive but mining exports for example, cannot be promoted through VAT because prices and demand for copper are determined at the London Metal Exchange and other international markets. Zero rating exports should, therefore, be targeted and reserved for Non- traditional exports.

Alternatively, since the VAT refunds have largely been claimed mining houses (estimated at 76%,), the easy way out could be Zero rate both the input and output of the mining industry unlike now where the Output (exports or sales) is zero rated but the input (imports and whatever they mines use in production) is standard rated at 16% and thus are able to claim refunds,

Thirdly, there is need to improve the cash management of VAT in order to avoid the cash flow problems that ZRA faces. It is advisable that in order to avoid having VAT arrears, the introduction of prudent accounting practice by ensuring that VAT funds are not comingled with other taxes but banked in separate bank account accounts will be a solution to the refund conundrum.

The issue of VAT refund fraud is a major problem but other countries have found solutions to it. One of the most efficient Tax authorities in Africa is South Africa Revenue Service (SARS). They are sophisticated and have minimized VAT fraud. It would be advisable for ZRA to send a study team to SARS to go and learn tricks on how to catch the cheats as SARS have immense experience in a more sophisticated economy.

In the event that the Government still wants to go ahead with Sales tax, it may be advisable for them to shelve the whole decision for a year or so. On the basis of the author’s experience in a foreign country as an Advisor, when major policy decisions with immense impact on the economy were at hand, studies were conducted and widespread consultation made in order to make informed decisions. The knee jerk approach to major economic decisions can be disastrous and embarrassing when reversals are made. It may be advisable for the government to commission an independent study by professional consultants to carry out an in- depth analysis to address some of the issues raised in this article and by others. Thereafter, an informed decision could be made after serious consultations with stakeholders and the people in the know.

The advice to government is that VAT is a good tax regime and should be retained. The areas that have been the cause of the problems should be addressed. The costs of switching from VAT to Sales tax far exceed the benefits. The risks are also immense. If Sales tax is implemented against all advice from experts, it will join the long list of economic own goals or unforced errors committed by the current administration- to use football and tennis analogies- which have resulted in the mess the Zambian economy is today. The abolishment of VAT and replacing it with Sales tax is tantamount to the proverbial “throwing the baby with the bath water”.

The writer is a Chartered Accountant by profession, a Private Sector Development expert and an Enteprenuer. He is an independent finance and economic commentator/analyst and a Patriot.

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40 COMMENTS

  1. Well articulated. ..better and understandable from a lay mans standing…. But ba EAZ has failed even GRZ through the Ministry has failed to explain what exactly they intend to do, the benefits and repercussions of the sales tax…….

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    • The length of this piece is it’s own undoing.

      Let me summarize for you. PF gabament have borrowed beyond means to repay, and in their desperation have been behaving like a dog chasing it’s own tail while the “infestors” make hay.
      The only glimmer of intelligence in this piece is that Zambia is indeed a nation of street vendors, no manufacturing at all.

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    • When did Nkonde ever say anything positive about the smart people of the Zambian Enterprise.

      All the development that has taken under his nose the last 2 decades are nothing to him. He wants more and more and more without willing to pay for it.

      The Notre Dame Cathedral in Paris almost burned down to ashes yesterday. The giant structure took 182 years to complete.

      A lot of people that started working on it died along the way but successive groups soldiered on and on and on!!

      From the 12th Century into the 13th, they worked like it would be completed the next day. Great legacies take time to build.

      Kalima here is from the microwave generation, he placed at order at one McDonald window and a minute later he’s picking up his McChicken on the other window.

      It took Europe 700…

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    • Continued …

      It took Europe 700 years to reach civilization, it took America 150 years to be called an industrialized country, Japan 45 years with the help of everyone after WWII.

      Even Europe borrowed $130Billion from the United States after WWII to rebuild under the Marshall Plan so, borrowing is not systematic only to Zambia.

      Nobody is helping us to build our country as much as other nations that have made it did but by God we are doing it the best way we know how … Heaven help us all.

      Epo mpelele,

      BRM

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    • By the way most accounting softwares have parameters whereby one has to choose what tax bracket and system is in place already built in so you simply change the settings for new parameters.

      On ZRA “TAX EXPERTS” who are these people … it’s a two day seminar to retrain and you can do this in batches. This reminds of Sarah Sanders saying Congress is not smart to understand Trump’s taxes when in fact Congress actually writes tax law.

      Yaba … it’s on record that the MMD’s introduction of VAT is what actually killed our UNIP era manufacturing base we built under KK.

      Finally, guys like Kalima here run small import-export businesses on the side. That 16% VAT refund for them is guaranteed capital inflow for them in case their suppliers clients take long to pay.

      This VAT has been an…

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    • Continued …

      Finally, this VAT refund thing has been an insurance policy for them to continue being in business and now that’s about to be taken away from them.

      That’s why you see all this opposition all of a sudden because they realize that cash cow is about to be obliterated.

      Epo mpelele,

      BRM

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    • @BR Mumba, Sr is indeed shallow, he does not know that with the advancement of science and technology , development is supposed to be faster. Apart from f00lishness, there is no reason PF govt has failed to mechanise farming despite technology available for combined harvesters and automated farming solutions. Botswana and Rwanda have developed on their own in 20years due to focused leadership with a vision. Mumba is a typical example a villager whom you cannot take away the village from them despite his many years cleaning toilets and sweeping roads in the USA

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    • @Obatale … for your information I worked with Quick Books to automate some of those functions I alluded to while I was in graduate school for accounting and finance so I know exactly what I am talking about and you have zero point of reference whatsoever.

      As for cleaning toilets … I have been so blessed never to make such a thing as part of my CV. But I want to let you know I have respect for someone who cleans toilets for an honest wage than a wanna be pretending to be Mr. Know it all like Obatale here.

      Epo mpelele,

      BRM

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    • B.R Mumba, could you tell us one policy by the PF that has been implemented and is growing the economy since they assumed power in 2011. Thanks.

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    • @Dudelove … I have visited Zambia 3 times since 2011 and I have seen that the fastest growing segment of its GDP is construction and consumer spending.

      The average GDP per capita has almost doubled in some cases quadrupled compared to when I left Zambia in the 90’s.

      Another sector that has grown exponentially is commercial farming. I have noticed that Mkushi for instance is a hive of activity with white farmers owning their own airstrips with runways better than even some government owned airports.

      The sad part is that almost zero Zambian is taking part in that kind of development. Almost all of it is foreign driven. How come foreigners are prosperous in the same space the natives are complaining from?

      Epo mpelele,

      BRM

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    • BR Mumba commercial farming has always been on an upward trajectory even before PF so that is nothing new and cannot be alluded to PF policies since under PF the costs of inputs have skyrocketed and taxes have risen so I have no idea on what basis you are marrying govt policy to strides by commercial farmers in growing. Educate me. What specific policies are in place that are helping the farmers?

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    • Not an extent that I have personally witnessed since 2011. Yes, commercial farming had always been there not to the current unprecedented levels, I repeat.

      As for what specific policies go figure … there must be government driven initiatives that are working for those foreigners that should work for natives as well.

      The problem like I specified is that natives and foreigners are living in the same space and one group is prospering while one is not and do you know why?

      Because foreigners are not looking specifically to GRZ to feed them, they realize this is a capitalist economy and they go out there breathing the same air, drinking the same water driving on the same roads but making a difference for themselves in spite of GRZ’s policies.

      Ask not what your country can do for…

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    • Continued…

      Ask not what your country can do for you rather ask what you can do for your country ~ President John Fitzgerald Kennedy.

      If PF sucks so much then by all means kick them out of office. You the people run this country not the politicians.

      Heaven help us all …

      Epo mpelele,

      BRM

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    • For your information, I am looking forward to coming back to Zambia soon. Every time I visit I feel a new sense of optimism for my people.

      On a micro level, the smart people of the Zambians Enterprise have really changed, they are more hard working than at any time in history.

      The only time I can compare their resilience to is probably in the late 70’s. When KK used to make it almost mandatory that we all worked hard. Dads worked hard, Mums worked hard, children worked hard at school.

      Townships and suburbs were empty during the day because all of us were out working hard either at school, college or work. It’s was the best time for burglaries to occur … during the day.

      Because everyone was gone from home busy working … my last visit 2 years ago was almost nostalgic with…

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    • Continued…

      Because everyone was gone from home busy working … my last visit 2 years ago was almost nostalgic with streets almost empty like before. It was so when I visited in the early 2000’s under Chiluba.

      People were walking all over aimlessly.

      Epo mpelele,

      BRM

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    • BR Mumba, your optimism and good cheer are outstanding, but unfortunately the majority Zambians do not feel that way because all you have tabulated has not manifested in terms of uplifting the standards of living of the common Zambian. They are worse off than they were under MMD and that is a fact. PF have no policies directly aimed at improving people’s lives. Their focus right now is servicing a debt whose results we cannot see. Look at ZESCO crying to raise tarrifs to ‘cushion against the harsh economy’ words of their spokesperson but they received part of the eurobond. ZR is not better off than before after receiving the eurobond so in short, BR Mumba, your sentiments are good and progressive on paper, but there has been zero trickle down effect to the commoner.

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    • @Dudelove … I fully understand and trickle down economics only works for those who aggressively put themselves out there to achieve on their own and not free loaders.

      That’s why in a pure capitalist economy the poor get poorer and the richer get rich. The system is rigged and the top 1% control the wealth of the entire 99%.

      I am no advocate of communism nor socialism but those societies are better placed to lift those falling behind.

      When we kicked UNIP out of power we wanted to create for ourselves a capitalist economy where the invisible hand pulled levels of commerce.

      Now, you are advocating for government intervention because no pure capitalism exists … this is what KK referred to when you called him Fonko!!!

      He told you mu kafonka pamala and you didn’t believe…

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    • Continued…

      He told you mu kafonka pamala and you didn’t believe him. We can’t go back now so only highly innovative minds are going to survive and the average Zambian understands that.

      That’s where my optimism comes from, that’s why I referred to the average GDP per capita rising being a good thing because from there you can built the middle class and the rest would be history.

      It’s not GRZ’s job to create a manufacturing base anymore, you see an opportunity and you create a good and/or service I need and I buy it from you and vice versa.

      That’s the kind of economy we are in and those expecting GRZ to do things for them will forever be at the bottom of the pole.

      Epo mpelele,

      BRM

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    • I would hardly call the majority of Zambians free loaders. Zambia has got extremely hardworking people, I see them hustling everyday, the women who wake up at 4 in the morning for orders, the farmers killing themselves in the fields. All these people still hustled the same way under MMD but they had sustainable lives because the cost of doing business was very manageable due to sound Government policies that included cushioning effects like subsidies. You can be an aggressive businessman but if Government is determined to milk all your small efforts through continuous taxes then there will be no improvement. PF have no clue. PF have no plan. The sooner you accept this the better. At this rate even UNIP surpasses this government in terms of policy and caring for people.

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    • @Dudelove … my point exactly when I referred to being elated during my last visit because I saw it for myself how the work culture has tremendously improved.

      And if PF is the problem, I repeat … by all means kick them out of office in the next election cycle!!! Go out there start mobilizing, organize and campaign for people whose policies you believe will help people’s plight.

      That’s your number 1 civic responsibility as a citizen … to guard jealously what you believe is positive posterity for future generations.

      You don’t bury your head in the sand and just hope for the best, you proactively engage your neighbors, your friends and family because you want to leave a better Zambia than the one you found for your children and children’s children.

      Epo mpelele,

      BRM

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    • People who don’t want government to collect more taxes from these infestors should declare interest and not just claim to be experts.
      The mines who are the biggest claimers of VAT refunds are the ones sponsoring these self declared experts to write articles that will excite dull chaps who don’t understand that capitalism and stealing are the same thing.

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  2. Ba Kalima Nkonde, I have always loved reading your articles. They are well articulated. Please, as the patriot that you are continue providing the country with your expert advice.

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    • I admire this type of talent in people. You know how to go about it with explanations and illustration. But you can not add one’s PAYE to sales tax paid on say bathsoap and claim a worker will in the month end up paying 35% + 41%. This is very misleading.

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  3. Why they don’t listen to non partisan patriots like Kalima? I already told kicking of GST at 9% would be disastrous, unprecedented.

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  4. Well articulated. In addition, sales tax encourages corruption especially for goods that have a long chain just to avoid the higher taxes down the line.

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  5. Taxation ladies and gentlemen is a complex matter. Factors like which sectors of the economy are contributing more to GDP of the country have a major role in determining the suitable tax regime in an economy. According to this article, if 70% of VAT refunds($4b x 70% = $2.8b in 6 months) relate to the mining sector, what does it tell you about the significance of the Mining sector to Zambia`s GDP. We can as well say this is the only ”manufacturing” sector this country can boast about. ”Manufacturing” raw minerals. Looking at the author`s proposals in a bit of detail exposes the country`s economy to the following challenges:
    1. He proposes to exempt the Mining sector from VAT;
    The immediate and direct implication is that the cost of mining in Zambia will go up by 70%- none…

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  6. refundable VAT, per example above by $2.8b in 6 months. How does this impact on the profitability of the mining sector. Will the mines survive in Zambia, think of job losses and ripple effect on PAYE that will immediately vanish. How about the whole economy and especially industries that support mining sector would also not survive and hence more revenue losses. Clearly this is no solution at all.
    2 He Proposes VAT Zero rating on Mining related inputs and Outputs.
    This would have a zero effect as far as the mining sector is concerned and probably a better option to consider. However, it will immediately deny the Govt cash flow of $2.8b in 6 months which at the moment is collecting and using before the VAT refunds are made. On average VAT refunds are made after a bout 60 days to 90…

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  7. “if a Zambian manufacturer imports raw materials he will pay 16%, on selling to a wholesaler, 9% local sales tax will be levied, when the wholesaler sales to a retailer, 9% will be levied and when a retailer finally sales to the consumer, 9% will be charged. This means that the Zambian final consumer- the farmer, villagers, informal sector worker, they will be paying 41% tax instead of 16 % VAT.”

    It would be more then 50%:
    If ZMW100 worth of raw materials is imported the worth of the materials would be 100*1.16=116 If the goods are sold to a wholesaler the worth would be 116*1.09 = 126.44 than to a retailer 126.44*1.09 = 137.81 than to the consumer 137.81*1.09 = 150.21.

    I have abstracted any profit margin by the selling parties for simplicity.

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  8. days from the invoice date. The Govt will need alternative source of revenue to fill up this cash flow gap. On that basis from the Govt side this is not desirable option as they are able to use short term interest free VAT credit facility which is so consistent every month. Actually this makes one of the advantages of VAT for Govt.
    MY VIEWS. I agree with the writer that a well managed VAT regime is far better for both GOvt and business. The operational, technical and mechanism of VAT must be understood correctly and properly by tax policy setters to appreciate that it is an economically friendly tax that encourages investments. It fits in squarely in a fair tax system. The major advantage that differentiates VAT from other taxes is its ability to automatically give relief to business…

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  9. Tax consultants and advisers with vast experience in VAT driven advanced economies can help. Although Zambianization is in itself a good thing, there is need to avoid to blend international and domestic brains. Clearly, there were brain deficits in the administration of VAT. The solution to brain deficits is to remove them from the system. Indeed, distortions are just that: distortions. They are calling for rectification without attacking the system. By definition, systems are neutral. A bad carpenter blamed his tools.

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  10. through the input tax credit system because by its nature VAT is payable by the final consumer in the line of distribution. For me it is a better tax than sales tax and given a choice I would choose it and improve the administrative part of it. As for this Govt`s decision to revert back to sales tax is all about collecting more revenue to pay back huge debts regardless of the negative effects this tax has on businesses and the citizens. Unfortunately, this may have negative impact even on other taxes. I wish I could write more.

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  11. what has caused VAT problems is corruption among ZRA officials.They get commissions with some ministers.
    Zambia should promote manufacturing.Why should u steal and invest in lodges instead of manufacturing companies.All these politicains don’t think about having manufacturing companies but simple buildings.U can’t build an economy like that.Come with manufacturing companies ba lungu.Youths are dying coz they can’t be employed by govt coz there is no money.It’s only manufacturing companies which can absorb unskilled labor bane.Let us think.Mwanakatwe lacks good idea to make this country forward.Change the minister of finince not bamayo balya.she just knows English but she lacks idea to move the economoy of this country.Mutati was even better despite being an ACCA b y professional.

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  12. Learn to listen and listen to learn. Yes we understand that there ought to be the first one but one can set a bad lesson. A few cheats in this game should not cause ZRA to change its method of Tax collection without considering the consequences as outlined in the advice above given. One writer once said that “you do not send a swallow to catch a rat in a sewer. You send a bigger rat”. in this case, you simply have to find experts who can outrun the cheaters in their game. If I may ask once again, where are our past Finance ministers to comment on this matter? Are they equally blank?

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  13. “Sales tax is implemented against all advice from experts, it will join the long list of economic own goals or unforced errors committed by the current administration- to use football and tennis analogies- which have resulted in the mess the Zambian economy is today.”

    Like the S.I.s of Hon Chikwanda and Sata’s mulamu Fredson Yamba Secretary to the Treasury which abolished pricing in foreign currency. Shamelessly withdrawn after much damage to businesses and the national economy. And shockingly that S.T. is still in place!! Could he also be behind this tax regime? He could be telling us “You ain’t seen the last of me”.
    That is PF for you, even complex economic matters are reduced to and directed like party cadre matters.
    Not that trib.al Hacks is any better, his thinking is…

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  14. …Not that trib.al Hacks is any better, his thinking is purely trib.al whereas PF thinking is purely party cadre.

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  15. I think both view points have merit. I have difficulties with people that disrespect a contrary opinion and sink low to name calling and or patronising. Lets be adults for goodness sake! I think the main rationale for 16 pc tax on imports is to encourage import substitution and promote local. Companies must innovate to be competitive and survive. As for the traditional supply chain, its now old relic of medevial days. Today the manufacture sales directly to chain stores to the consumer. The wholesaler of today has to be frugal, efficient to be in business. In the vat system the importer levied the tax and so did everyone along the chain up to consumer and then reverted to Cesar for some cooked up refund. In the end my very capable youngman Chanda at ZRA was harmstrung by an unwieldly…

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  16. we both have those traditional picture frames and digital picture frames at home. both are great for displaying family pictures;;

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