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    A. Income Tax: Scheme of the Act

    The Act provides for a series of steps to be followed in arriving at the taxpayer's taxable income. The starting point is to determine the taxpayer's gross income [as defined in s 8 (1)]

    Gross Income means - the total amount of income, in cash or otherwise, received by or accrued to or in favour of such person from a source within or deemed to be within Zimbabwe during the year of assessment.

    Receipts or accruals of a capital nature are generally excluded from gross income. However, certain amounts, irrespective of their nature, are specifically included in the definition of gross income under specific subparagraphs (a) to (s) in (s 8) regardless of whether they might be of a capital nature or not.

    The next step to be taken is to arrive at income, which is the result of deducting all receipts and accruals that are exempt from tax under the Act from Gross Income in terms of (s 14) as read with the 3rd Schedule of the Income Tax Act.

    Finally, taxable income; is arrived at by deducting all the amounts allowed to be deducted in terms of (s 15) as read with the 4th and the 6th Schedule of the Income Tax Act from income;.

    (Taxable capital gains are calculated and taxed separate from other income - See Section I, below)

    The steps to be followed in determining taxable income are thus:

    Gross Income

    Minus Exempt Income

    = Income

    Minus Deductions

    = Taxable Income/Assessed Loss

    B. Income Tax on Resident Corporations (National Government)

    1. Name of Tax and Levied in Terms of Which (Name, Number and Year)

    Income Tax, Income Tax Act, (Chapter 23:06) (hereinafter referred to as “the Act”).

    2. Department Responsible for Administration

    Zimbabwe Revenue Authority (hereinafter referred to as (ZIMRA).

    3. Definition and Classification

    The term “company” is defined in s 2 of the Act, it includes: any association wheresoever incorporated. This definition is not restricted to a company with limited liability.

    4. Basis of Taxation

    4.1 Source-based or residence based

    Zimbabwe has a source-based income tax system. It is essential to note that no amount is gross income unless it is from a Zimbabwean source or is deemed to be from such a source (Section (8) (1)).

    4.2 If source, define:

    4.2.1 Actual source

    The Act itself contains no definition of the term ‘source’. To determine the source of an amount the Courts apply a two pronged test namely

    (a) the originating cause of the amount

    (b) the geographic cause of the amount.

    The originating cause can either be the business of the taxpayer or employment of capital, assets or funds or both. The source is located in the country where these activities are carried out or where the capital is employed.

    It is generally accepted that the profits from business operations have their source where such operations are conducted.

    4.2.2 Deemed source

    Deemed source is that source which is not in Zimbabwe but is considered to be in Zimbabwe as specified under section 12 of the Income tax act [Chapter 23:06.]

    Examples:

    (a) Amounts received or accrued under any contract made in Zimbabwe for the sale of goods regardless of the country of their origin or of delivery.

    (b) Amounts received or accrued for services rendered by a person in the carrying on of a trade in Zimbabwe is taxable irrespective of whether the person rendering the services is resident in Zimbabwe or where the amount is paid.

    (c) Amounts received or accrued for services rendered as an employee outside Zimbabwe by a person ordinarily resident in Zimbabwe during a period of temporary absence from Zimbabwe.

    (d) Amounts received for services rendered to the state, irrespective of where the services were rendered

    (e) Annuities from a foreign source if at time of acquiring the annuitant was ordinarily resident in Zimbabwe.

    It is generally accepted that the profits from business operations have their source where such operations are conducted.

    4.3 If residence, define:

    4.3.1 Define resident

    4.3.2 Exclusions from the definition of resident:

    4.3.3 Ceasing of residency provided for in the Act

    5. Time Tax is Levied

    Tax is levied on the earlier of the date of receipt or accrual. The term ‘accrued’ has been interpreted by the Courts as the date on which a person becomes entitled to an amount, i.e when the amount becomes due and payable.

    6. Included in Tax Base

    Income from a Zimbabwean source or deemed source.

    7. Year of Assessment

    Means a period of 12 months beginning on the 1st January in any year and includes any period within such a year of assessment. For periods before 1st April 1997 a year of assessment is a period of twelve months beginning on the 1st April in any year.

    8. Computation of Taxable Income

    8.1 Exemptions

    Exemptions are provided for by Section 14 as read in conjunction with the Third Schedule of the Income Tax Act (Chapter 23:06).Exemptions are classified either by the identity of the recipient or by nature of a receipt and accrual.

    8.1.1 Partial exemptions (amounts exempt irrespective of the identity of the recipient):

    Para 10

    Amounts accruing by way of interest paid on:

    (a) any savings certificate issued in terms of any law;

    (b) a sum deposited in the Post Office Savings Bank of Zimbabwe;

    (c) any tax reserve certificate issued in terms of the tax Reserve Certificates Act [Chapter 23:10];

    (d) A loan raised by the state subject to the condition that interest on the loan shall be exempt from income tax;

    (e) any loan made by the European Investment Bank established by Article 129 of the treaty establishing the European Economic Community;

    (f) any loan to the Zimbabwe Development Bank established by Section 3 of the Zimbabwe Development Bank Act [Chapter 24:14] made by an institutional shareholder as defined in that Act who is not ordinarily resident in Zimbabwe;

    (g) any so called “agricultural bond” issued by the Agricultural Finance Corporation and a consortium of commercial banks; and

    (h) any bond issued by the Reserve Bank of Zimbabwe on behalf of the National Fuel Investment Company P/L.

    Para 10A.

    Any amount accruing by way of interest as defined in the 21st Schedule.

    Para 11

    Interest received by or accrued to a person who at the time of accrual is not ordinarily resident or does not carry on business in Zimbabwe, is exempt for taxation if it accrues on loans:

    (a) made to miners or prospectors and the loan is used by them for mining operations in Zimbabwe;

    (b) made to the state or any company wholly owned by the state, and for the purpose of this subparagraph, loan includes any form of indebtedness known as acceptance or standby credit facility;

    (c) to local authorities;

    (d) to statutory corporations, and for the purpose of this subparagraph, loan includes any form of indebtedness known as acceptance or standby credit facility;

    (e) made before the 16th July 1976, to a Building Society.

    The above exemptions do not apply where:

    i. if the country of ordinary residence of the person receiving the interest will tax the interest merely because it is exempt from tax in Zimbabwe.

    ii. the person, either ordinarily resident or carrying on a trade in Zimbabwe causes such interest to accrue to a company under his control.

    iii. the interest is from a subsidiary company in Zimbabwe to a foreign holding company and taxable in another country in which Zimbabwean tax is allowable as a credit.

    Para 13

    Amounts derived from the sale of traditional beer if such beer is sold in terms of the Traditional Beer Act (Chapter 14:24), are exempt from taxation to the extent that such profits are used in the manner in which the person licensed to sell the beer uses them as required by the said Act.

    Para 14

    An amount paid by the state to an exporter of goods in terms of a scheme for the development of export trade, excluding the amount of any duty refunded in terms of the Customs and Excise Act [Chapter 23:02]

    Para 16

    The receipts and accruals of a licensed investor from the investment to which his investment licence relates in the year of assessment in which he first commences operations in an export processing zone and in each of the following four years of assessment.

    Para 17

    The receipts and accruals of an industrial pack developer to the event that they accrue directly from the operations of an industrial park (as defined) in the earlier of the year of assessment in which the industrial park is established or is approved by the Minister and in each of the next four following years.

    Para 18

    An amount received by way of the sale, disposal or transfer of any duty free certificate issued by the Reserve Bank of Zimbabwe to exporters qualifying for a rebate of duty on imports in terms of Section 128C of the Customs and Excise (General) Regulations 1997.

    8.1.2 Absolute exemptions (taxpayers enjoying completed exemption from tax on income):

    In terms of Section 14(1) as read with the Third Schedule receipts and accruals of the following organization are exempt.

    Para 1:

    (a) Local Authorities;

    (b) The Reserve Bank of Zimbabwe;

    (c) The Zambezi River Authority;

    (d) The National Resources Board; and

    (e) The Post Office Savings Bank.

    Amounts paid to individuals employed by those organisations by way of salaries, wages, allowances, etc from the receipts and accruals of those organisations are not exempt from taxation in the hands of such individuals.

    Para 2:

    The receipts and accruals of –

    (a) agricultural, mining and commercial institutions or societies not operating for the private pecuniary profit or gain of the members;

    (b) Benefit funds;

    (c) Building societies;

    (d) Clubs, societies, institutes, associations and organizations operated solely for the social welfare, civic improvement, pleasure, recreation or the advancement or control of any profession or trade other similar purpose. If such receipts or accruals, whether current or accumulated may not be divided amongst or credited to the benefit of any member or shareholder other than by way of remuneration for services rendered;

    (e) Ecclesiastical, charitable and educational institutions of a public character;

    (f) Employee saving schemes or funds approved by the Commissioner;

    (g) Friendly, benefit or medical aid societies;

    (h) Funds established by the Treasury in terms of section 30 of the Audit and Exchequer Act [Chapter 22:03];

    (i) Pension funds until such date as the Minister may specify by notice 17 of Gazette;

    (j) Any statutory corporation which is declared by the Minister by notice 17 the Gazette to be exempt from income tax. Provided that the Minister may limit any such declarations to such of the statutory corporation’s receipts and accruals as he may specify in the notice;

    (k) Trade unions; and

    (l) Trusts of a public character.

    Para 3:

    The receipts and accruals of:

    (a) Any agency of any government other than the Government of Zimbabwe approved by the Minister by notice in a statutory instrument;

    (b) Any international organization specified in terms of Section 7 of the privileges and immunities Act which has been approved by the Minister by notice in a statutory instrument [Chapter 3:03];

    (c) The organization referred to in the International Finance Organisation Act [Chapter 22:09];

    (d) The African Development Bank referred to in the African Development Bank (Membership of Zimbabwe) Act [Chapter 22:01];

    (e) The African Development Fund referred to in the African Development Fund (Zimbabwe) Act [Chapter 22:02];

    (f) Any foreign organization that provides finance for development in Zimbabwe, to the extent that its receipts and accruals are from a project approved for the purpose of this subparagraph by the Minister;

    (g) Any bank or other financial institution outside Zimbabwe in connection with a loan or other facility granted to the Reserve Bank of Zimbabwe in terms of paragraph (m) of subsection (1) of Section of the Reserve Bank of Zimbabwe Act [Chapter 22:10]; and

    (h) Any company which has as its principal object the provision of venture capital for development purposes and which is approved by the Minister by statutory instrument.

    8.2 Deductions and recoupments

    8.2.1 Allowable deductions

    General Deduction formula (Section 15(2)(a))

    Deductions shall be allowed in respect of expenditure and losses to the extent to which they are incurred for the purposes of trade or in the production of income, except to the extent to which they are expenditure or losses of a capital nature.

    Capital Allowances (Section 15(2)(c))

    This section allows for the deduction of Capital Allowance in respect of both movable and immovable assets as detailed in the Fourth Schedule.

    Lease Premiums (Section 15(2)(d))

    An allowance in respect of any premium or consideration for the use of movable and immovable assets, and intellectual property shall be allowed as a deduction.Lease improvements (Section 15(2)(e))An allowance of the value of improvements effected in terms of a lease agreement granting the right of use of land or buildings.

    Bad Debts (Section 15(2)(g))

    Amounts of bad debts due to a taxpayer that became bad during the year of assessment is deductible provided that the amount was included in the taxpayer’s income in either the current or any previous year of assessment.

    Expenses on Experiments and Research (Section 15(2)(m))

    This section allows for the deduction of expenditure incurred in respect of experiments and research related to the trade of the taxpayer during the year of assessment. The research must be carried out by the taxpayer and payment to another is not sufficient unless the taxpayer has full control and direction of the research.

    Grants, Scholarships or Bursaries (Section 15(2)(p))

    Any sum contributed by the taxpayer during the year of assessment in the form of a grant, bursary or scholarship to enable any person not connected with the taxpayer to take a course of technical education related to the trade of such taxpayer at any educational institution is deductible.

    Annuity, Allowance or Pension (Section 15(2)(q))

    This section provides for the deduction of annuities, allowances and pensions paid to former employees or partners who have retired and also to dependants of deceased former employees or partners.

    Donations to certain funds or charitable trust (Section 15(2)(r))

    This section provides for the deduction of amounts donated to the National Scholarship fund or the National Bursary Fund which are set up through an Act of Parliament or to a charitable trust administered by the Minister of Health or Social Welfare.

    Export Market Development Expenditure (Section 15(2)(gg))

    A deduction is allowed of any export-market development expenditure incurred by the taxpayer during the year of assessment.

    8.2.2 Valuation of inventory/trading stock

    8.2.3 Reserves and provisions

    8.2.4 Non-deductible expenses

    8.2.5 Recoupments

    8.3 Depreciable regime

    8.3.1 Tangibles (movable and immovable assets, for example plant and machinery)

    8.3.2 Intangibles/incorporeals (for example, copyright, patents, goodwill and other intellectual rights)

    8.4 Treatment of losses

    9. Foreign Exchange Losses and Gains

    Foreign exchange losses and gains (Section 8(2) and Section 15 (1))

    Profits or losses arising from changes in the rate of exchange, are brought to account in the year of assessment in which they are realised.

    10. Branch Profits Tax

    The section dealing with branch profit tax was repealed by section 12 of Act 29 of 1998 with effect from 1st January 1999.However, tax is payable at the rate of 20% on remittances to headquarters by Zimbabwean branches of foreign corporations in respect of foreign expenses allocated to the branch operation.

    11. Group Taxation/Consolidated Returns

    No group taxation.

    12. Presumptive Tax Measures (for example, a minimum tax in the form of a gross asset tax)

    No presumptive tax.

    13. Rates

    14(2)(c) Taxable Income of a company or Trust 25%

    14(2)(d) Taxable Income of Pension Fund from Trade or Investment 15%

    (Paragraph 2 (i) of the 3rd Schedule exempts the taxability of pension funds at the moment. This exemption will last until such date as the Minister may specify that such income is now taxable, by notice in the Government Gazette).

    14(2)(e) Taxable Income of a licensed investor (After the 5th year of operation) 15%

    14(2)(f) Taxable Income of holder of a special mining lease. 15%

    14(2)(f1) Taxable Income of company or trust derived from mining operations. 25%

    14(2)(g) Taxable Income of a person engaged in approved Boot arrangement :

    • 1st 5 years of the arrangement 0%
    • 2nd 5 years of the arrangement 15%
    • 3rd 5 years of the arrangement 20%

    14(2)(h) Taxable Income of industrial Park developer (after 5th year of operation) 10%

    14(2)(i) Taxable Income of operation of a tourist facility in approved tourist development zone:

    • 1st 5 years of the operation 0%
    • 2nd 5 years of the operation 15%
    • 3rd 5 years of the operation 20%

    14(3) Taxable Income of a person engaged in new Manufacturing project in a growth point area. 10%

    14(3a) Taxable Income of person engaged in new project providing infrastructure in growth point areas. 15%

    14(3b) Taxable Income from Manufacturing or processing of company which exports 60% or more of its output. 20%

    14(3c) Taxable Income from operation of tourist facility in approved tourist development zone 60% or more of whose turnover consists in foreign currency receipts. 20%

    14. Rebates

    None.

    15. Withholding Taxes

    See section E of this chapter

    16. Beneficiaries of Revenue

    Zimbabwe Government.

    C. Income Tax on Individuals (National Government)

    1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year Income Tax, Income Tax Act Chapter 23:06 (hereinafter referred to as “the Act”).

    2. Department Responsible for Administration Zimbabwe Revenue Authority

    3. Definition and Classification

    “Individual” means a person other than a company.Under Zimbabwe law a partnership does not have a separate legal existence, but taxes are levied on the individual partners.

    4. Time Tax is Levied

    Tax is levied on the earlier of the date an amount is received or it accrues. The terms “accrued to” has been interpreted by the Courts as the date on which a person becomes unconditionally entitled to an amount, i.e. when the amount becomes due and payable.

    5. Basis of Taxation

    5.1 Source-based or residence based

    Zimbabwe has a source-based income tax system. It is essential to note that no amount is gross income unless it is from a Zimbabwean source or is deemed to be from such a source.

    5.2 If source, define:

    5.2.1 Actual source

    Same as for bodies corporate.

    5.2.2 Deemed source

    Same as for bodies corporate.

    5.3 If residence,

    5.3.1 Define resident

    5.3.2 Exclusions from the definition of resident:

    5.3.3 Ceasing of residency provided for in the Act

    6. Included in Tax Base

    Income from a Zimbabwean source or deemed source.

    7. Year of Assessment

    The year of assessment for individuals covers a period of 12 months and commences on 1 January and ends on the 31st of December

    8. Computation of Taxable Income

    8.1 Exemptions (do not only indicate the heading, but provide a brief explanation)

    8.1.1 Partial exemptions (amounts exempt irrespective of the identity of the recipient):

    Same as for bodies corporate. In addition section 14 as read with the 3rd Schedule of the Income Tax Act (Chapter 23:06)) provides for an exemption in respect of:

    • Bonus or performance related award to the extend that it does not exceed 10% of one's annual remuneration, or US$400 whichever is greater (Para 4 (o));
    • The first US$5 000 or 1/3 which ever is greater of a retrenchment package provided that no exemption shall apply to amounts above $15 000 (Para 4 (p));
    • Benefits or advantages enjoyed by employees of a licensed investor to the extent that they do not exceed 50% of such employees; taxable income before the inclusion of such benefits or advantages (Para 4(q));
    • Entertainment allowance received by an employee but only to the extent that it is expended on the business of the employer (Para 15);
    • Salary and emoluments paid in respect of his office to the President and members of the staff of the President in so far as such salary and emoluments are paid by the President (para 4);
    • Amounts derived by persons who are entitled to exemption or relief from income tax in respect of such salary or emoluments in terms of the:

    i. Privileges and Immunities Act [Chapter 3:03]

    ii. in terms of any agreement entered into by the Government of Zimbabwe with any other government or international, regional or foreign organization and is approved by the Minister by notice in a statutory instrument;

    • Specified allowances and gratuities payable to specified officials in respect of duties performs for or on behalf of the state;
    • A scholarship, bursary, payment in respect of tuition fees or other educational allowance to a student receiving instructions at a school, college or university, but not including an amount accruing to the student by way of remuneration for services rendered or to be rendered by the student or a near relative of student.
    • Various specified other accruals (para 11), for example interest received by or accrued to or in favour of a person who at the time the interest accrues is not ordinarily resident and does not carry on business within Zimbabwe;
    • An amount received by way of alimony (par 12);
    • An amount received by or accrued to or in favour of an employee participating in an approved employee share ownership scheme or trust from the sale to or redemption by the scheme or trust of any stock, shares, debentures, units or other interest of the employee in the scheme or trust (par 19).

    8.1.2 Absolute exemptions (taxpayers enjoying completed exemption from tax on income)

    Same as for bodies corporate.

    In addition the receipts and accruals of any person entitled to an exemption in respect of an agreement between the Government of Zimbabwe and any other government or organization which is approved by the minister through a statutory instrument is exempt from tax (Section 14(1) as read with para 3 of the Third Schedule).

    8.2 Deductions and recoupments

    8.2.1 Allowable deductions

    As for bodies corporate.However, deductions against income from employment is restricted to:pension contributions, subscriptions to professional associations and cost of essential tools for trade. Various credits in respect of medical expenses and disability are also allowed against tax on employment income.

    8.2.2 Valuation of inventory/trading stock

    Same as for bodies corporate.

    8.2.3 Reserves and provisions

    Same as bodies corporate.

    8.2.4 Non-deductible expenses

    The following expenditure incurred by individuals is not allowable as a deduction in terms of the Income Tax Act (Chapter 23:06):

    1. Private maintenance costs (S16 (1) (a))The cost incurred by the taxpayer in maintaining himself, family and/or establishment is not deductible. This includes the expenses incurred in traveling between home and the place at which he carries on trade, and where the taxpayer carries on two or more trades, which are distinct in nature, the cost of traveling between those two places is not deductible.

    Otherwise as for bodies corporate.

    8.2.5 Recoupments

    Same as for bodies corporate

    8.3 Depreciable regime

    8.3.1 Tangibles (movable and immovable assets, for example plant and machinery)

    Fourth Schedule

    Same as for bodies corporate.

    8.3.2 Intangibles/incorporeals (for example, copyright, patents, goodwill and other intellectual rights)

    Same as for bodies corporate

    8.4 Treatment of losses

    Treatment of Losses (Section 15(3))

    Section 15 (3) allows the deduction from income of any assessed loss determined in respect of the previous year of assessment.

    • An assessed loss is the amount which the allowable deductions exceed the taxpayer;s income and this includes the amount of loss brought forward from the previous year (s 2(1));
    • Amounts received by or accrued to any taxpayer under a contract of employment shall not be taken into account for the purposes of determining his assessed loss (s 2 (1) read with s 15 (8));
    • Assessed losses are cumulative.Instances where assessed loss may not be allowed as a deduction (s15(3)):
    • where the taxpayer has been declared insolvent or has made an assignment of his property or estate for the benefit of his creditors;
    • Change in the shareholding of a company with an assessed loss effected solely or mainly in pursuance of or in connection with any scheme for taking advantage of such assessed loss.

    No loss can be carried forward for more than six years except for mining companies.

    9. Foreign Exchange Losses and Gains

    Same as for bodies corporate.

    10. Rates

    Section 7 (b) read with S 14(2)(b) of the Finance Act (Chapter 23:04)

    Taxable Income of individual from trade or investment 25%

    Other rates, please see rates for bodies corporate above.

    Section 7 (b) read with S 14(5) of the Finance Act (Chapter 23:04)

    Tax Table Per Month (US$)

    Taxable Income (US$)

    Tax Rate (%)

    0 to 160

    0

    161 to 500

    20

    501 to 1000

    25

    1001 to 1500

    30

    1501 and above

    35

     

    Thereafter deduct credits and add 3% aids levy

    11. Rebates/Tax Threshold

    The following credits are applicable to individuals:

    a. Disabled persons credit of US$900 p.a.

    b. Blind persons credit of US$900 p.a.

    c. Medical expenses credit of 50% of cost of medical expenses and contributions. There is no limit on the amount claimed as a credit.

    Credits are deducted from the income tax with which a person is chargeable in terms of Section 5 of the Finance Act (Chapter 23:04).

    12. Fringe Benefit Taxes (Benefits Flowing from an Employer-Employee or an Office Relationship)

    Any advantage or benefit in respect of employment is included in an employees gross income in terms of the definition of gross income whether paid in cash or in kind.

    Specific provisions provide the basis of arriving at the value that must be placed upon each benefit. The major valuation methods are value to the employee or cost to the employer.Benefits that constitute taxable free benefits include:

    i. Asset acquired at less than actual/market value

    ii. Right to use of an asset (other than a motor vehicle or residential accommodation)

    iii. An allowance.

    A taxable benefit arises whenever an employee is granted the use of an asset either free of charge or for consideration which is lower than the open market value of the asset.

    • Right of use of motor vehicle (S 8(1)(f)(ii))

    The benefit or advantage arises when an employee uses the employers vehicle for private purposes this includes distance between home and place of work. Unless proved otherwise by the person entitled to use the vehicle or where the Commissioner considers the cost to be greater, the benefit to the employee shall be deemed to be:-

    Deemed Benefit (US$)

    Engine Capacity

    1 800 

    Up to 1500 cc

    2 400

    1 501 cc to 2 000 cc

    3 600

    2 001 cc to 3 000 cc

    4 800

    Exceeding 3000 cc

     

    • Residential accommodation

    The taxable advantage benefit arises from the occupation or use of quarters, residence or furniture by reference to its value to the employee less any sub-economical rents paid by the employee; this includes holiday accommodation.

    • Interest free and low interest loans

    If an employer grants a loan to an employee, the benefit arises when that loan is interest free or attracts a rate lower than the specified interest rates (on loans of up to $XXX its 12,5% and on loans of over $XXX its 16%).

    13. Allowances

    See 12 above.

    14. Treatment of Pension, Provident or Retirement Annuity Fund Income

    1. Annuities received from these funds are taxed as ordinary income. The capital portion of a purchased annuity is exempt from tax ( Section 8(1)(a));

    2. Lump-sum benefits derived from these funds are taxable, subject to a certain portion being tax free (Section 8(1)(c) read with the First Schedule);

    3. Any amount received by way of commutation of a pension or annuity in excess of one third of the pension or annuity paid by a Retirement Annuity Fund is brought into gross income (Section 8(1)(n));

    4. Taxation of commutation of pension or annuity from consolidated revenue fund or a pension fund (excluding a Retirement Annuity Fund) provided it exceeds:

    i. 1/3 of total value of pension or

    ii. $60 000, whichever is the greater amount (Section 8 (1)(r)).

    An employee may claim the following deductions:

    1. Contributions made in the year of assessment to a benefit fund or pension fund or the Consolidated Revenue Fund. The current maximum pension contribution allowable is $45 000 (Section 15(2)(h) and the 6th Schedule).

    2. The amount of any arrear contributions which are paid by the taxpayer in respect of past services with his employer to a pension fund other than a retirement annuity fund or to the Consolidated Revenue fund but the arrear contributions are deducted up to a certain limit. (Section 15(2)(i)).

    It should however be noted that no contribution to a retirement annuity fund shall be allowed as a deduction to a member of such a fund who was not ordinarily resident in Zimbabwe at the time he made the contributions unless:

    a. he was ordinarily resident in Zimbabwe at the time he became a member of the fund;

    b. he became a member of the fund before the 1st April 1967.

    15. Treatment of Professional Income

    There is no special treatment for professional income, it forms part of gross income under Section 8.

    16. Treatment of Investment Income

    a) Interest is taxed as a special fixed rate of 20% and this is a final tax.

    17. Withholding Taxes

    See section E.

    18. Beneficiary of Revenue

    The Government of Zimbabwe.

    D. Income Tax on Non-Residents (National Government)

    1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

    Same as for resident taxpayers. The Zimbabwean Act does not specifically provide for taxation of non residents.

    2. Department Responsible for Administration

    Same as for resident taxpayers

    3. Included in Tax Base

    Same as for resident taxpayers

    4. If Sourced-Based, Define (If Not Already Done)

    4.1 Actual source

    Same as for resident taxpayers

    4.2 Deemed source:

    Same as for resident taxpayers

    5. Rates

    Same as for resident taxpayers

    6. Beneficiary of Revenue

    Same as for resident taxpayers

    E. Income Tax: Treatment of Dividends, Interest, Royalties and Fees

    1. Dividends

    The term dividend is defined to mean any amount which is distributed by a company to its shareholders in terms of 9th Schedule (para 1(1)) and 15th Schedule (para 1(1)). The following are specifically excluded from the definition:

    i. Building society Paid Up Permanent Shares (Class C);

    ii. any bonus;

    iii. a return on a company’s shares;

    iv. any amount distributed by IDC of Zimbabwe;

    v. any amount distributed by Zimbabwe Development bank in terms of ZDB Act (Chapter 24:14);

    vi. any amount distributed to the International Finance corporation;

    vii. any amount so distributed by a licensed investor;

    viii. A return of an amount contributed to the capital of a private business corporation by a member; and

    ix. Any amount distributed by an industrial park developer.

    Section 26 as read with the 9th Schedule to the Income Tax Act Chapter (23:06).

    Dividends distributed by a local company to non-resident shareholders attracts a Non – Residents’ Tax (Withholding Tax) at the rate of 20%. The tax rate of 20% is the maximum applicable, but may be varied downwards depending on whether the country receiving the dividend has a Double Taxation Agreement with Zimbabwe.

    Section 28 as read with the 15th Schedule to the Income Tax Act (Chapter 23:06)

    Dividends distributed by a local company to local shareholders attract a Resident Shareholders’ Tax at the rate of 20%

    Section 12 (2) of the Income Tax Act (Chapter 23:06) as read with Section 14 (5) of the Finance Act (Chapter 23:04).

    Dividends derived from a source outside Zimbabwe which are received by or accrue to a person are deemed to be income from a source within Zimbabwe if the person is ordinarily resident in Zimbabwe at the time the dividend amount is received or so accrues, and shall be charged to tax at 20%.

    2. Interest

    The Act does not contain a definition of the term ‘interest’ for general purposes

    Resident Tax on Interest Section 34 as read with 21st Schedule.

     

    Interest means any interest from a source within Zimbabwe payable by a financial institution on any loan or deposit but excludes:

    i. Interest paid on Class C building Society shares;

    ii. Interest payable to another financial institution;

    iii. Interest payable to a money lender who holds a licence;

    iv. Interest payable to persons exempt under paragraph 1, 2, 3, and 10 of the 3rd Schedule;

    v. Interest payable to a registered insurer;

    vi. Interest on payable on an FCA account held by an individual.

    The rate of tax on resident interest is 20% and this is a final tax.

    Non Resident on Tax on Interest – Section 29 read with the 16th Schedule.

    Interest means any interest from a source within Zimbabwe and includes dividends distributed by Building Societies in respect of shares other than specified Building Society shares, and excludes:

    (i) Exempt Interest,

    (ii) Interest in respect of the Government of Zimbabwe Settlement term annuity;

    (iii) Interest forming part of an annuity;

    (iv) Interest payable to any payee whose receipts and accruals are exempt;

    (v) Interest payable to a licensed investor or industrial park developer.

    The rate of tax is generally 20% but also dependant on whether the country of residence of the recipient has a Double Taxation Agreement with Zimbabwe.

    3. Royalties

    Section 8 (1).

    Royalties derived by a Zimbabwean resident are treated as ordinary business income.

    Section 32 and the 19th Schedule.

    Royalties paid to non Zimbabwean resident are subject to withholding tax.

    The withholding tax does not apply to amounts derived from-

    (a) any project which is specified by the Minister by Notice 9 Statutory Instrument or

    (b) any project which is the subject of any agreement entered into by the Government of Zimbabwe with any other government or international organisation in terms of which any person is entitled to exemption from tax in respect of such amount.

    The withholding tax is calculated at 20% of the gross royalty, but also depends on whether the country of residence of the recipient has a Double Taxation Agreement with Zimbabwe.

    4. Fees

    Section 8 (1).

    Fees derived by a Zimbabwean resident are treated as ordinary business income.

    Section 30 and the 17th Schedule.

    Fees payable to a non-resident are subject to withholding tax in terms of Section.

    Fees means any amount from a source within Zimbabwe payable in respect of a service of a technical, managerial, administrative or consultative nature to a non resident.

    The fees are deemed to be from a source within Zimbabwe if the person responsible for payment (payer) is ordinarily resident in Zimbabwe.

    The fees are also deemed to have been paid to the non-resident (Payee) if they are credited to his account or dealt with in such a way that the conditions governing his entitlement have been fulfilled.

    The withholding tax is calculated at 20% of the gross fees but also depends on whether the country of residence of the recipient has a Double Taxation Agreement with Zimbabwe.

    5. Rents

    Section 8 (1).

    The Act does not contain a definition of the term ‘rent’.

    Rent derived by a resident from properties located in Zimbabwe are treated as ordinary income.

    F. Income Tax: Specific Industries

    1. Mining Tax

    “Mining operations” is defined in Section 2 of the Act as:

    (i) any operation for the direct mining of minerals form the earth; and

    (ii) any operation for the winning a mineral from any substance carried;

    (iii) on in conjunction with the direct operations referred to in (i) above; and

    (iv) operation for the winning a mineral from any substance or constituent of the earth.

    Section 8 (1).

    Income from mining operations by a company or trust is 25%. Mining operators enjoy special allowances detailed in the 5th Schedule and section 15(2)(f).

    Section 15 (2)(f).

    i. In lieu of capital allowances, lease premiums, lease improvements and pre production expenses, a deduction is allowed in respect of allowances detailed in the 5th Schedule provided that such allowances are claimable in respect of expenditure or losses attributable to particular mining locations.

    3 (1) (a)

    A company which works a mine which is not its property is entitled to deduct, for each year of assessment, an allowance based the estimated life of the mine or the period of the tribute whichever is lesser as fixed by the Commissioner.

    2. Insurance Business

    In the case of a person carrying on the business of insurance it is provided by this section that the part of his taxable income or assessed loss which is attributable to such business of insurance is to be determined in accordance with the provisions of the 8th Schedule. The taxable income or loss so determined is then treated in accordance with the general provisions of the Act

    3. Farming

    Section 8 (1)

    Income from farming is taxable at the rate of (30%) and is taxable under section 8 (1).

    In addition to deductions generally provided for in the Act, special deductions applicable to farmers are provided for in section 15 (2)(z) as read with the 7th Schedule.

    7th Schedule paragraph 2.

    The expenditure incurred by a farmer on:

    • Stamping and clearing;
    • Soil erosion prevention;
    • Boreholes and wells;
    • Aerial and geophysical surveys
    • Water conservation, and
    • Fencing is allowed as a deduction against income.

    The allowance is granted to a taxpayer on assets actually constructed by him.

    Paragraph 3.

    A timber farmer may elect that the following rules shall apply in determining the taxable income or assessed loss in respect of timber growing operations:

    a. the cost of planting the timber shall be carried forward until the timber has reached maturity;

    b. add yearly an amount of 5% of the cost of planting to the first cost of planting until the timber reaches maturity;

    c. on sale of the timber, whatever amounts have been accumulated in respect of a and b above, shall be deducted from the sale proceeds, and the residue will form taxable income;

    d. an amount as determined in b above shall be added to taxable income or deducted from an assessed loss as the case may be, in each year of assessment;

    e. expenditure incurred on maintenance and upkeep of such timber, including deductions for capital allowances, premiums and expenditure incurred in pursuance of an obligation to effect improvements on land or to buildings, shall be deducted from taxable income or added to an assessed loss as the case may be.

    f. Where the timber farmer elects that the above rules apply to the determination of his taxable income, such election is binding for all subsequent years of assessment.

    Should the farmer not elect to be taxed under the above rules, the income from the timber operations are taxed in the normal way, where taxable income is arrived at by first establishing the gross income, less exemptions and less deductions.

    An election made in terms of para 3 is binding for all subsequent years.

    Farmers can also claim capital allowances in terms of section 15(2)(c).

    Paragraph 5 of the 7th Schedule

    A farmer in a drought-stricken area who is compelled, by reason of the conditions, in his area, sell his livestock is entitled to elect that the taxable income derived from such sales be taxed in three equal installments commencing with the year of assessment in which the livestock were sold. If however, such taxable income exceeds his total taxable income, he may elect instead to spread the latter over three years.

    Paragraph 6

    This paragraph provides for an outright allowance of 50% of the cost of livestock purchased by a farmer in a drought-stricken area in order to restock a herd depleted by death or forced sales during a period of drought.

    The allowance is, of course, over and above allowable in terms of section 15(2)(a). Note that the allowance is reduced if the livestock purchased exceeds the difference between the assessed carrying capacity of the land and the number of livestock on hand immediately prior to the date of such purchase.

    4. Ships and Aircraft Owners

    No special provisions are applicable to ships and aircraft owners.However, income derived by the owner of a ship or aircraft from a Zimbabwean source is taxable in Zimbabwe subject to provisions of Double Taxation Agreements.

    5. Other

    Section 21 and the 20th Schedule provides for the taxation of income of petroleum operators.

    Section 22 and the 22nd Schedule deal with the taxation of income of holders of special mining leases.

    G. Income Tax: Administrative Procedures (National Government)

    1. Payment Periods

    PAYMENT PERIODS - Section 71.

    The Commissioner is empowered to fix the date, time and place where tax is to be paid, failure of which, interest is chargeable at a specified rate.

    Section 72

    Taxpayers whose taxable income has not been subject to employees tax in terms of the 13th Schedule, shall be liable to pay provisional tax on that amount in three installments. The provisional installments called Qurterly payment dates (QPDs) are paid as follows:

    (a) 1st QPD, 10% of the provisional tax payable, to be paid on or before 25th March of therelevant year of assessment;

    (b) 2nd QPD, 25% of the provisional tax payable, to be paid on or before 25th Juneof the relevant year of assessment;

    (c) 3rdQPD, 30% of the provisional tax payable, to be paid on or before 25th Septemberof the relevant year of assessment and

    (d) 4th and lastQPD, 35% of the provisional tax payable, to be paid on or before 20th of Decemberof the relevant year of assessment.

    The Commissioner may, by written notice prescribe different dates from those specified above.

    Section 73 read with the 13th Schedule.

    Paragraph 3 (1).

    Every employer who or becomes liable to pay remuneration to an employee shall withhold from that amount employees tax (PAYE) and shall pay the withheld amount to the Commissioner within 15 days or any extended period not exceeding 21 days after the end of the month during which the amount was withheld.

    Paragraph 20A

    The Commissioner may direct any employer to deduct employees tax from the remuneration of his employees in such a way that the amount so withheld in any one year is equal or nearly equal to the income tax payable by the employees in that particular year of assessment.

    2. Rulings

    2.1 Possibility of advance rulings

    None

    2.2 Publication of rulings

    None

    3. Codification of Revenue Practices

    ZIMRA publishes Practice Notes.

    4. Refunds

    Section 48.

    When the Commissioner is satisfied that a taxpayer has overpaid tax, he may authorise a refund. The refund must be claimed within six years after the date of the assessment. If the taxpayer owes any other tax, the Commissioner is entitled to set off the refund against the tax owing.

    Where a taxpayer had been assessed in accordance with a practice generally prevailing at the time shall be deemed to have been properly chargeable.

    5. Interest, Charges and Penalties

    Section 71(2)

    Where tax is not paid on or before the date fixed by the Commissioner, interest calculated at 35% per annum shall be payable on the tax or installment of the tax that remain unpaid during the period from the date fixed up to the time when the tax is fully paid.

    Section 46.

    The penalty for an offence under this section is an amount equal to double the normal tax applicable to the default or omission.

    Section 81

    The penalty for offences under this section are a fine not exceeding $XXXX or an imprisonment term for a period not exceeding 3 months.

    Section 82

    Penalties under this section amount to a fine of $XXXX or a jail period not exceeding 6 months or to both such fine and jail term.

    Section 83

    People previously convicted under sections 81 and 82 the penalty shall be, in addition to any punishment be liable to a fine not exceeding $500.00 a day for each day that he is in default or to imprisonment for a period not exceeding 12 months.

    Section 84

    Penalty same as section 81 except for the imprisonment which is for a period not exceeding 12 months.

     

    Section 85

    A fine not exceeding $XXX or imprisonment for a period not exceeding 18 months or both.

    Section 86

    A fine not exceeding $XXXX or jail term not exceeding 3 years or both.

    9th Schedule paragraph 6.

    100% of such non-resident shareholders tax.

    13th Schedule paragraph 22

    A fine not exceeding $XXXX or a jail term not exceeding 6 months or both.

    Paragraph 23

    A fine not exceeding $XXX for each day that he is in default or to imprisonment for a period not exceeding 12 months.

    The Commissioner may reduce the penalty as he sees fit, if he is satisfied that failure to pay was not motivated by intention to evade tax.

    H. Income Tax: Anti-Avoidance Provisions (National Government)

    1. Transfer Pricing Legislation

    (S16 (1)(q)).Expenditure incurred by a local branch or subsidiary of a foreign company, or by a local company or subsidiary of a local company, in servicing debts contracted in connection with mining operations to the extent that such debts cause the person to exceed a debt equity ratio of 3 to 1 is not allowable as a deduction.

    2. Thin Capitalisation Legislation

    (S16 (1)(q)).Expenditure incurred by a local branch or subsidiary of a foreign company, or by a local company or subsidiary of a local company, in servicing debts contracted in connection with mining operations to the extent that such debts cause the person to exceed a debt equity ratio of 3 to 1 is not allowable as a deduction.

    3. Controlled Foreign Entities (CFES)

    Not applicable

    4. Provide a Brief Discussion of General Anti-Avoidance Provisions (Both under common and statutory law)

    Common law

    A scheme set up for a purpose other than tax avoidance can still be attacked if it is operated for tax avoidance, and that tax-avoiding action taken by an accountant can be imputed to his client, the taxpayer. (L v C of Taxes, 37 S.A.TC. 116: Lev v. C of Taxes, J. 36)

    The phrase “the effect of avoiding……….. liability for any tax” was held to mean avoiding liability for tax by getting out of the way of, escaping from or preventing an anticipated liability.

    (Smith v. C.I.R. S.A.T.C. 1)

    Section 98

    Where a transaction, operation, or scheme has been entered into or carried out, which has the effect of avoiding or postponing liability for tax or reducing the amount of such liability, was entered into or

    i. carried out in a way which would not normally be employed, or

    ii. created rights which would not normally be created between persons dealing at arms length and the Commissioner is of the opinion that avoidance or postponement of such liability was the sole or one of the main purposes of the transaction, operation or scheme, the liability of any tax shall be determined as if that transaction was never entered into.

    5. Transactions Between Connected Persons

    No specific provisions, but see 1 above.

    I. Capital Gains Tax on Corporations (National Government)

    1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year)

    Capital Gains Tax Act, Chapter 23:01.

    2. Department Responsible for Administration

    Zimbabwe Revenue Authority.

    3. Basis of Taxation (Source-based or residence-based)

    Source-based tax.Disposal of specified assets by any person within Zimbabwe are subject to Capital Gains Tax. Specified assets means immovable property or any marketable security, including shares in private companies.

    4. Time When Tax is Levied

    On disposal as defined in Section 6 of the Capital Gains Tax Act. Special rules determine the time of disposal as contained in the Act. The time of disposal of an asset is in the case of change of ownership-

    • If there is an agreement subject to a suspensive condition i.e. ownership shall pass from the seller of the whole or a certain portion of the amount payable the asset will be considered to have been sold on the date of the agreement.
    • If there is an agreement not subject to a suspensive condition the date on which the agreement is concluded.
    • Where an asset is sold on credit (paid in installments) and ownership passes the date of the agreement.
    • Where an asset is donated the date of donation

    5. Included in Tax Base

    A gross capital amount from a source within Zimbabwe.

    6. Exemptions/Exclusions

    Section 10

    1. The receipts and accruals of bodies mentioned in paragraphs 1, 2, and 3 of the 3rd Schedule of the Taxes Act;

    2. Amounts received or accrued on the disposal of any marketable security in respect of any loan to a local authority, statutory corporation or 100% state owned company;

    3. Amounts received or accrued on the sale by a petroleum operator of immovable property used for petroleum operations to another petroleum operator for the same purposes;

    4. Amounts received or accrued on the sale of shares in the Zimbabwe Development Bank by an institutional shareholder who is not ordinarily resident in Zimbabwe;

    5. Amounts received or accrued on the sale by a person carrying on life insurance business of assets which are an investment in Zimbabwe; and

    6. Receipts and accruals of a licensed investor or an Industrial Park Developer from the sale of an asset forming the whole or part of the investment to which his investment license relates.

    7. Allowable Deductions

    Section 11.

    (a) Expenditure incurred in the acquisition or construction of the specified asset and on improvements additions or alterations of these assets;

    (b) 30% inflation allowance is allowed on the costs of acquisition or construction, additions, improvement or alterations of the specified assets;

    (c) Expenditure directly incurred in connection with the sale of the specified asset;

    (d) Bad debts if amount was included in the current year of assessment or was included in any previous year of assessment in the taxpayers capital amount;

    (e) Costs incurred and taxed by the Registrars in connection with an appeal to the High Court or Supreme Court;

    (f) If amount of capital gain is $XXXX or less then an amount equal to that total amount is deductible;

    (g) From the amount of the capital amount remaining after deducting the above deductions these shall be deducted an assessed capital loss carried forward from the previous year;

    8. Non-Deductible Expenses

    (Section 12)No deduction shall be made in respect of expenditure on or in relation to a specified asset the sale of which is exempt from tax.

    9. Roll-Overs

    Rollover (postponement of tax) is allowed under following circumstances:(Section 15)

    Transfer of a specified asset between companies under the same control.

    Section 17

    Transfer of business property by an individual to a company under his control.

    10. Treatment of Losses

    Section 11 (3)

    Capital losses can be carried forward except where:

    i. there is a deliberate shareholding change to take advantage of the assessed capital loss;

    ii. a taxpayer has been adjudged or has become insolvent.

    Capital losses carried forward from the previous year of assessment are also deductible.

    11. Rates

    (1) 11. Rates.

    On disposal of a marketable security listed under the Zimbabwe Stock Exchange 10%

    On disposal of a principal private residence by a person of 60 years of age or above 10%

    In any other case other than those mentioned above 20%.

    12. Rebates

    None

    13. Tax Period

    Same as for Income Tax.

    14. Withholding Taxes

    Section 22C of the Capital Gains Act (Chapter 23:01) as read with Section 39 of the Finance Act (Chapter 23:04).

    Any amount paid by a depository as a result of the sale or transfer of a specified asset, shall be withheld from it:

    - In the case of immoveable property, 10% of the price at which the property was sold;

    - In the case of a sale of a marketable security that is listed on the stock exchange, 5% of the price at which the security was sold;

    - In the case of a security other than a security referred to above, 10% of the price at which the security was sold.

    (Withholding taxes on marketable securities had been suspended until such a date as the Minister may specify by notice in the Government Gazette).

    15. Beneficiary of Revenue

    The Zimbabwe Government.

    J. Capital Gains Tax on Individuals (National Government)

    1. Name of Tax and Levied in Terms of Which Levied (Name, Number and Year)

    Capital Gains tax Act Chapter 23:01 of 1996.

    2. Department Responsible for Administration

    Zimbabwe Revenue Authority

    3. Basis of Taxation (Source-based or residence-based)

    Actual Source in Zimbabwe

    4. Time When Tax is Levied

    On disposal of the Immovable Property or Marketable Security (including shares in private companies).

    5. Included in Tax Base

    6. Exemptions

    Section 10

    (a) Receipts and Accruals of bodies referred to in paragraphs 1,2 and 3 of the third Schedule to the income Taxes Act Chapter 23:06;

    (b) The receipts and accruals of a licensed investor or Industrial Park Developer from the sale of an asset forming the whole or part of the investment to which his investment licence relates;

    (c) amounts received or accrued on the disposal of a specified asset forming part of a deceased estate by an executor;

    (d) Amounts received or accrued on the sale of any marketable security being any bond or stock in respect of any loan to –

    • the state or any company all the shares of which are owned by the state;
    • a local authority;
    • a statutory corporation.

    (e) Amount received or accrued on the sale by a person carrying on life insurance business as defined in subparagraph (1) of paragraph 1 of the Eighth Schedule to the Taxes of specified assets which are investment in Zimbabwe for the purposes of factor F or G in the formula in paragraph 6 of that Schedule.

    (f) Amounts received or accounts on the sale by a petroleum operator approved by the Minister by notice in the Government Gazette of immovable property used for the purposes of petroleum operations to another petroleum operator.

    7. Allowable Deducations

    Section 11 of the Capital Gains Tax Act Chapter 23.01

    (h) Expenditure incurred in the acquisition or construction of the specified asset and on improvements additions or alterations of the said the specified asset.

    (i) 30% inflation allowance is allowed on the costs of acquisition or construction, additions, improvement or alterations of the specified assets.

    (j) Expenditure directly incurred in connection with the sale of the specified asset.

    (k) Bad debts if amount was included in the current year of assessment or was included in any previous year of assessment in the Taxpayers capital amount.

    (l) Costs incurred and taxed by the Registrars in connection with an appeal to the High Court or Supreme Court.

    (m) If amount of capital gain is $XXX or less than an amount equal to that total amount is deductible.

    (n) From the amount of the capital amount remaining after deducting the above deductions these shall be deducted an assessed capital loss carried from forward from the previous year.

    8. Non-Deductible Expenses

    Same as for bodies corporate.

    9. Treatment of Losses

    Section 11 (3) Capital losses can be carried forward except where:

    * a taxpayer has been adjudged or has became insolvent.Capital losses can be allowed as a deduction if:

    * they are carried forward from the previous year of assessment.

    10. Rates

    Same as for bodies corporate.

    (a) On disposal of marketable securities listed under the Zimbabwe Stock Exchange the rate of Capital Gains Tax would be 10%.

    (b) Sale of a principal private residence by an individual who has attained 59 years prior to the commencement of the year of assessment the rate of Capital Gains Tax would be 10%.

    (c) In any other case the rate of Capital Gains Tax is 20%.

    11. Rebates/Annual Deduction

    None

    12. Tax Period

    A withholding tax is applicable – see 13 below.

    13. Withholding Taxes

    (a) Withholding Taxes on Capital Gain does not apply to sales concluded before 1st January 1999.

    (b) Withholding Taxes on sale of marketable securities have been suspended until such a date as the Minister may specify by notice in the Government Gazette.

    (c) The duty to withhold Capital Gains withholding taxes has been given to the depositories, agents and payee.

    14. Beneficiary of Revenue

    The Government of Zimbabwe.

    K. Special Taxes (Other Than Income Tax) on Certain Industries/Types of Income

    1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

    i. Tobacco levy charged in terms of the Income Tax Act Section 36A as read with the 24th Schedule

    ii. Automated Financial Transactions Tax. Section 36B of the Income Tax Act as read with 25th Schedule.

    iii. Informal Traders Tax Section 36C of the Income Tax Act as read with 26th Schedule.

    iv. Demutualisation Levy in terms of Section 36D as read with 27th Schedule of the Income Tax Act.

    v. Carbon tax charged in terms of Section 36E as read with the 28th Schedule of the Income Tax Act.

    vi. Banking Institution Levy charged in terms of the Income Tax Act Section 36F as read with the 29th Schedule.

    2. Department Responsible for Administration

    The Zimbabwe Revenue Authority.

    3. Taxpayer

    Tobacco Levy.

    a. Every auctioneer shall withhold from the price payable for auction tobacco sold on his auction

    b. The auctioneer shall recover from the buyer a levy charged on tobacco sold on his floors.

    Automated Financial Transactions Tax.

    The user of the Automated Teller Machine.

    Informal Trader’s Tax.

    The informal Trader.

    Demutualisation Levy.

    The affected Insurance Company.

    Carbon Tax.

    The Insured person.

    Banking Institution levy.

    The Banking Institution.

    4. Included in Tax Base

    See 4 below.

    5. Tax Rate

    a. Tobacco levy: 11/2% of the selling price of the auctioned tobacco to both the seller and buyer.

    b. Automated Financial Transactions Tax: $XXX for each transaction for which tax is payable.

    c. Informal Traders Tax: 10% of each dollar of the rent upon which the tax is chargeable.

    d. Demutualisation levy: 21/2% of the amount on which the levy is payable.

    e. Banking Institution levy: 5% of each dollar of the net profit upon which the tax is chargeable.

    f. Carbon Tax:

    1. $XXXX in the case of a motor vehicle whose engine capacity does not exceed 1500cc;

    2. $XXXX in the case of a motor vehicle whose engine capacity exceeds 1500cc but does not exceed

    2000cc.

    3. $XXXX in the case of a motor vehicle whose engine capacity exceeds 2000cc but does not exceed

    3000cc.

    4. $XXXX in the case of a motor vehicle whose engine capacity exceeds 3000cc.

    6. Beneficiary of Revenue

    The Zimbabwe Government

    L. Taxation of Capital

    1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

    None

    2. Department Responsible for Administration

    None

    3. Taxpayer

    None

    4. Included in Tax Base

    None

    5. Tax Rate

    None

    6. Beneficiary of Revenue

    None

    M. Donations Tax (National Government)

    1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

    None

    2. Department Responsible for Administration

    None

    3. Taxpayer

    None

    4. Included in Tax Base

    None

    5. Tax Rate

    None

    6. Beneficiary of Revenue

    None

    N. Other (National Government) (National Government)

    1. Name of Tax and Levied in Terms of Which Act (Name, Number and Year

    2. Department Responsible for Administration

    3. Taxpayer

    4. Included in Tax Base

    5. Tax Rate

    6. Beneficiary of Revenue

    O. Relief From Double Taxation

    Comprehensive agreements for the avoidance of double taxation on the same Income are in force with -

    United Kingdom

    Sweden

    Netherlands

    Norway

    South Africa

    Bulgaria

    Federal Republic of Germany

    Germany Democratic Republic

    Mauritius

    Canada

    Poland

    France

    Malaysia

    Section 93 provides for relief from double taxation where no Double Taxation Agreements exist