Our take on the Zimbabwe Mid – Term Budget Review

Fiscal interventions to try and boost the economy and encourage productivity and revenue consolidation were put in place on 16 July 2020 by Finance Minister and these are:

  1. Tax Relief Measures  

PAYE Tax-Free Threshold

Tax free threshold has been raised from ZWL $2000 to ZWL $5000 per month. The highest marginal rate is 40% for above $100 000

Tax Exemption on Risk Allowance Earned by Frontline Health Personnel

COVID-19 Risk Allowances payable to this category of employees are exempted from tax for a period of twelve (12) months commencing from 1 April 2020

Incentives for the Victoria Falls Securities Exchange (VFSE) and Investors

Government’s plan to launch the Victoria Falls Securities Exchange, with a view to attract critical offshore capital to the economy

As part of the incentive package to facilitate establishment and full operationalisation of the exchange the following incentives for the Victoria Falls Securities Exchange and investors:

• Exemption from Corporate Income Tax for the VFSE;

• Exemption from Capital Gains Withholding Tax on disposal of shares listed on the VFSE

• A lower rate of 5% on dividends payable to non-resident investors on the VFSE.

Allowable Deductions on Health Related Donations

A number of corporates have demonstrated a lot of goodwill and sacrifice by donating various goods and services to strengthen the health delivery system and social support framework.

The maximum allowable deduction on donations by corporates to the local currency equivalent of US$100 000.

Tax Exemption on University Infrastructure Projects

In order to support university infrastructure development initiatives by the Infrastructure Development Bank of Zimbabwe (IDBZ), exempt from Income Tax, specified Student Accommodation Projects

with effect from 1 January 2021. The exemption will be granted subject to fulfilling prescribed conditions.

Tax Exemption on Domestic Tourists Accommodation

The hospitality industry is one of the sectors most affected by the Covid-19 pandemic, hence it is essential for Government to take a leading role in supporting revival of the sector. Domestic tourist accommodation will be exemption from VAT with effect from 1 August 2020

2. Revenue Enhancing Measures

Payment of IMTT on Foreign Currency Transactions

Current legislation exempts the transfer of money into and from Nostro foreign currency accounts from intermediated money transfer tax. Intermediated Money Transfer Tax will be extended to cover foreign currency transactions. For the avoidance of doubt, transactions conducted by organisations accredited in terms of the Privileges and Immunities Act (Chapter 3:03) remain exempt from IMTT.

Tax Free Threshold and Maximum Tax Payable per Transaction

In line with market conditions, Intermediated Money Transfer Tax (IMTT) free threshold has been reviewed from ZWL $100 to ZWL $300 with the free threshold extended to foreign currency transactions not exceeding US$5. The maximum tax payable per transaction by corporates has been reviewed from ZW$25 000 to ZW$50 000 on transactions with values exceeding ZW$2 500 000 and maximum tax of US$ 2 000 for foreign currency transactions with a value exceeding US$ 100 000.

Value Added Tax Recording of Electronic Transactions

In order to mitigate risk on fiscal revenue, as well as enhance transparency, all VAT Registered Operators to configure Fiscal Devices to capture all transactions in the currency of trade and also produce the respective invoice in the tendered currency.

Duty Exemption on Donations of Vehicles to Government by Development Partners

Exemption from customs duty, donated single and double cab trucks, in support of Approved Projects undertaken by Government Ministries and Departments.

3. Tax Administration

 Border Post Enhancement

The surge in traffic volumes has created opportunities for smuggling of goods. In order to curtail smuggling activities, ZIMRA has been empowered to introduce Anti-Smuggling Surveillance Drones at both designated and undesignated entry points.

Excise Duty on Fuel

In order to create a balance between optimal revenue collection and affordability of fuel, there is now an Automatic Excise Duty Adjustment Mechanism that reviews excise duty on a monthly basis to levels determined through a designated formula, with effect from 1 August 2020.

4. Customs Duty Exemption on Top Dressing Fertiliser

Top dressing fertilisers of 120 000 metric tonnes on accredited dealers for the 2020-21 summer cropping season will be exempted




Returning student refers to an individual who has lived in Zimbabwe before and returns to Zimbabwe once he/she completes a course of study.

The returning students rebate on importation of motor vehicle has over the years allowed them to afford to acquire and import motor vehicles into Zimbabwe at a rational cost.

It should be noted that for the returning student to qualify for the rebate certain conditions should be met as highlighted below.


The returning student must be above the age of 16 years and should have stayed outside Zimbabwe for a period of not less than 2 years. The time of arrival also determines whether or not the student qualifies for the rebate and this can only be established from the returning student.

The first time of entering Zimbabwe by the student after completing the course of study, immigration officers will ask the returning student if he or she wishes to claim the returning student status upon arrival at any entry point. If the students wishes to claim returning students status, the immigration officer will stamp his/her passport with RR which shows that he or she is a returning resident.

The stamp concludes the student’s first occasion of entry and will determine whether or not the student can claim the motor vehicle rebate.  If the student does not import the vehicle on first occasion as above-mentioned he or she forgoes the duty rebate. 

Additionally, ZIMRA will request the returning student to produce academic transcripts, certificates or any other confirmation to ascertain that he or she has indeed completed studies.

The rebate is therefore not available to returning students who have not completed their studies for whatever reason. The vehicle must be in physical existence and fully paid for by the returning resident before the time of his arrival. Therefore if one purchases the motor vehicle after his return he or she may not enjoy the duty rebate, unless one did not declare that he has returned for good.

However, the rebate has led to the abuse by third parties importing vehicles duty-free. This abuse has resulted in the government losing out potential revenue to these 3rd parties.

To curb this risk the government has put a maximum value of US$5000 so as to qualify for the rebate. If a student imports a motor vehicle exceeding this value he/she will forego the rebate and pay the full duty on the imported vehicle.

Conclusively, the rebate has been of great importance as it benefits returning students although this move tend to result in an increase in the importation of second-hand motor vehicles which may pose environmental impacts such as emissions.



Normally, the goods taken by the Zimra border officials under the Customs Act, 1962 are deliberately taken by the Customs department. However, in some cases where the seizure is not practicable, it may become necessary to detain the goods for investigation. The provisions for putting goods under custody are contained in Section 110 of the Customs Act, 1962.

The goods are detained for various reasons and at the instance of various agencies of the Department, such as the Directorate of Revenue Intelligence, the Directorate of Central Excise Intelligence, Narcotics Control Bureau and Directorate of Enforcement and even other agencies, like the Central Bureau of Investigation. Once an order for detention of goods is served to the owner of the goods, he cannot remove, part with, or otherwise, deal with the goods except with the prior permission of the proper officer of the Customs.

During the investigation and subsequent adjudication proceedings, if the contravention of provisions of the Customs Act, 1962 and other allied laws is established, the action is taken against the importers/ offending goods as provided in the law. Guidelines for expeditious Customs clearance/provisional release: To avoid delays in the release and minimize hardship to the trade if goods remain detained pending an investigation into any dispute in relation to assessment, customs number must have been activated.

Import/export goods are not to be detained unless prohibited as per the FTP and/ or under other allied laws. However, goods that may be prohibited for importing/exporting will depend on the following conditions;

  • Imports not complying with the specifications/conditions/requirements of various Orders/Acts (e.g. Livestock Importation Act, 1898, Prevention of Food Adulteration Act, 1954, etc.)
  • Where gross fraudulent practices are noticed and release of the goods may seriously jeopardize further investigations as also interests of the revenue. Further, any individual suspected to be prohibited in terms of quantity, value, and description will be seized for being liable to confiscation under the Customs. The Departmental officers will be held accountable for cases where detention of goods has been ordered on insufficient and weak grounds resulting in the unconditional release of detained goods in the adjudication stage itself, where importers have to suffer avoidable demurrage charges/loss by pilferage.

Rules on VAT Apportionment that every Zimbabwean business owner must know

Input tax is the tax paid on purchases by a registered VAT operator on goods or services acquired for use, consumption or supply in the production of taxable supplies including imports made for use, consumption or supply in the production of taxable supplies. Only persons who are registered for VAT, known as registered operators are permitted to claim input tax. They may either offset it against output VAT or recover it as a refund from the ZIMRA. Taxable supplies are supplied which are charged 15% VAT, known as standard-rated supplies and those charged to tax at 0% rate are called zero-rated supplies.

The third category of supplies is called exempt supplies and individual supplying 100% exempt supplies does not charge VAT on sales nor claim input tax. An operator making both taxable and exempt supplies (non-taxable supplies) during an accounting period can claim input tax in proportion to the taxable element only as fully explained below.

Theoretically, it is easy to account for input tax when an operator only makes taxable supplies or exempt supplies. In practice, an operator will make purely taxable supplies or purely exempt supplies only in exceptional circumstances. Such a mixture of supplies gives rise to one of the most problematic areas in any VAT system, namely the question of apportionment of input tax.

Apportionment refers to the fact that only a portion of input tax that was paid is claimable – the portion not claimable will be added to the expense which will be deductible for income tax purposes under Income Tax. Where input tax is solely attributable to taxable supplies, a trader is entitled to deduct it in full from the output tax due on his taxable supplies.

On the contrary, where input tax is wholly attributable to exempt supplies, none of it is claimable. This means that the use to which input is put is important. Where this is not possible, the input tax becomes residual input tax which must be allocated by way of apportionment.  

In the event that input tax being incurred is for mixed purposes, claimable portion is calculated according to the apportionment percentage by using an approved method by the Commissioner of the Zimbabwe Revenue Authority (ZIMRA).

The only approved method which may be used to apportion input tax in terms of the Act without prior written approval from the Commissioner is the turnover-based method. The turnover-based method should be applied as follows:

                     = Taxable supplies exclusive of VAT   x total input tax

                        Total supplies (taxable plus non-taxable supplies exclusive of VAT)

When computing the income or turnover certain elements should be considered such as the cash value of goods supplied under an installment credit agreement, supplies of capital goods or services which have been used for trade purposes and the value of any goods or services supplied for which input tax deduction is always prohibited, for example, income from sale of passenger motor vehicle are excluded.

A registered operator who wants to use some other method which is not the turnover based should seek the prior approval of the Commissioner. The Commissioner would need to be satisfied that such other method fairly and reasonably represents the extent to which goods or services are used or are to be used by the registered operator in making taxable supplies.

In other words, the method must suit the special circumstances of individual registered businesses or reflect the use made by the taxable person of the relevant goods or services in making taxable supplies. The courts have held that in order for a method to be regarded as fair and reasonable it should be “sensible”, “sane”, and “not asking for too much”..

For example, what may be considered a fair and reasonable basis for apportioning the rent could be the floor space. “Taxable floor space” for this purpose means areas of the building used for making taxable supplies of building space to customers. Meanwhile, taxpayers are warned that methods which are not turnover based should be used or applied with caution because they often change with time.

The use of multiple methods notwithstanding the behavior pattern of the applicable expenses should also be avoided. Furthermore, the method so selected should be based on the information that is in possession of the taxpayer without having to resort to hiring expensive third parties, such as valuators.

The Act provides for de minimis apportionment rules. This means if the proportion of an input tax claim exceeds a given amount or ratio the registered person would be allowed full or 100 percent input tax or refund. The main purpose of this rule is to simplify VAT administration and compliance for tax officers and taxpayers.

The VAT Act makes provision for such rule and provides that where the goods or services so acquired are used at least 90 percent for the purposes of making taxable supplies, the full input tax credit may be granted. This indicates that input tax should be apportioned when the intended use of goods and services in the course of making taxable supplies is less than 90% of the total intended use of such goods and services.

There are tax implications for not apportioning input tax where goods or services are acquired for use, consumption or supply in the making of mixed supplies. ZIMRA will disallow the undue input tax and levy penalties and interest.


Why Taxpayers must take advantage of Capital Allowances

In Income tax computation, expenditure is deducted if it has been incurred in the production of income for the purpose of trade. Expenditure on acquisition or construction of fixed assets known as Property, Plant, and Equipment (PPE) is not deducted but claimed against taxable income in the form of capital allowances over the useful life of the assets.

Capital allowances can be claimed by all persons deriving income from trade and investments namely sole traders, independent contractors, non -executive directors, partners, companies, and trusts with taxable income irrespective of the type of business undertaken. However, miners and petroleum operators have their own method of claiming capital expenditure.

Capital allowances allow the taxpayer to obtain relief on capital expenditure by deducting it against pre-tax income. If an asset is constructed or acquired in one tax year then put into use in the following year, capital allowances are only claimed in the year the asset has been put into use.

Capital expenditure includes the cost of acquiring or construction of the asset and all costs related in acquiring the asset such as initial set up, installation, programming, travel cost to purchase the asset, freight charges, transit insurance, irrecoverable VAT, borrowing cost, foreign exchange losses in respect of the asset.

There are two methods of claiming capital expenditure namely Special Initial Allowance (SIA) and Wear & Tear (W & T). SIA is a capital allowance granted upon election on constructed buildings, additions, alterations or improvement to the said buildings and movable purchased.

The act provides for 90 percent de minimis use rule, meaning that property used for at least 90 percent in the production of income for purposes of trade to be granted SIA.

The current rate for SIA is 25 percent for annum for big business and 50 percent for SMEs in the first year. After the first year, accelerated wear & tear is 25 percent per annum for the next three years in the case of big business and 25 percent per annum for the next two years for SMEs.

SIA is never apportioned, either taxpayer qualifies or does not qualify for SIA at all and it is also computed based on cost. Assets under a finance lease also qualify for SIA in the hands of the lessee.

Wear and tear is granted in all cases where SIA has never been granted. It is computed on the cost of immovable assets purchased or constructed by the taxpayer, additions, alterations, and improvements made to immovable properties and on movable property including on computer software acquired or developed. The following are rates for wear and tear on;

  • Commercial buildings – 2.5% per annum
  • Immovable property – 5 %per annum
  •  Movable property and computer software -10% on written down values.

Wear and tear is apportioned in the case of movable property used partly for business and private by the owners of the business.

Accelerating capital allowances allow taxpayers to minimize their tax liabilities, making SIA a favorable method to claim wherever possible. However, it is not beneficial for taxpayer with assessed losses which are about to expire to elect SIA because it will result in increased assessed losses which may not be recovered.

Therefore, capital allowances are incentives on capital expenditure which taxpayers must take advantage of, but it is difficult to claim these when an individual is not a registered taxpayer or has no internal system for tracking capital expenditure.


Why it is Mission-critical for your Businesses to Conduct Tax Health Checks Frequently

The tax environment is ever changing and regulations are constantly evolving. Owing to this, businesses need to keep up by thoroughly assessing their tax structures, tax positions and tax compliances on an on-going basis, to ensure that the overall tax positions are backed by adequate support, compliances are monitored, and matters that are under litigation are dealt with appropriately.

What is a tax health check?

A tax heath check is a systematic review of your business’ records and accounting systems with a view to identify any areas of risk in relation to the collection or recording and reporting of data used to produce reports to any Government revenue office (ZIMRA) as well as to assess opportunities that have not been taken advantage of, for example incorrect reporting or not utilising alternatives available through the tax system leading to too much tax being paid. In effect, it gives confidence in the level of risk the business has in relation to taxation.

Tax health checks provide an assurance that tax implications for a certain period, an area of compliance, or a specific transaction are identified, duly addressed, and in following through, appropriate action are taken for risk mitigation. Conducting such health checks on a periodic basis will help in managing tax risks, ensure appropriate compliance, and result in better preparedness for litigation matters and strengthen tax positions.

The Key Focus Areas for a simple tax health check

Tax Audit Risk

A tax audit is an inspection of the correctness of the tax accounting with the aim of identifying and hedging potential tax risks arising from violation of different requirements. Furthermore, a tax audit is an efficient tool for optimising the tax liability, offering real options for improving economic results. An analysis of risks inherent in the different tax areas, including but not limited to, corporate income tax, value added tax, wage accounting, is done to check for compliance with statutory registrations.  A regular tax health check will expose all non-compliance issues before the organisation has been flagged for an audit by ZIMRA and penalties imposed on them.

Corporate Governance

This is also a critical area in conducting a health check. Corporate governance is the system by which companies are directed and controlled. Everything from communication to leadership and strategic decision-making. Primarily, however, it involves the board of directors, how the board conducts itself and how it governs the company. The shareholders’ role in governance is to appoint the directors and the auditors and to satisfy themselves that an appropriate structure is in place.

It takes an external party to be impartial in analysis of processes and note the loopholes than those in the system. This is why organisations find it easier and efficient to outsource such activities to firms that specialise in this.

The Small to Medium Sized Business: is there a case for a tax health check?

Compliance issues are universally applicable regardless of the size of a business and as an owner of a small business, it is even more important that you are found compliant by ZIMRA. This is because non-compliance has far reaching effects. Multiple researches on SMEs is Zimbabwe have found that most enterprises in this bracket are non-compliant, and with a sizeable number of them forming the back-bone of the country, this poses a serious challenge to the economy. A regular occurrence in SMEs is that of lack of adherence to corporate governance procedures leading to inefficiencies, unethical practices, tarnishing of corporate image when such issues are exposed, legal penalties, and disregard of procedures especially in situations where the founding owners are part of the board. Absence of regular checks therefore expose these enterprises to overtaxation.

Access to such vital information in a small business may not be readily available. This is what companies such as ourselves are passionate about. We identify issues through understanding of management activities and industry-specific activities, assess accurate classification and tax treatment, perform a comprehensive review and analysis of major accounts and transactions, provide in-depth review of issue-specific laws and regulations and quantification of potential tax effect.

We also develop appropriate solutions to minimize possible tax exposures and risks, assist with requests for rulings or interpretations by tax authorities on issues in question or dispute to minimize risks of uncertain tax liabilities from a possible challenge by the tax authorities. This is in addition to performing comprehensive reviews of tax reconciliation to ensure all opportunities to reduce tax liability or to obtain refund of overpaid tax have been explored. Further, we identify areas where tax exemptions or reductions may be utilized to reduce future tax liability and through all this process offer sound business advice to ease your way of doing business.

It is one thing to conduct a successful health check for an organisation but the important thing is also to then put forward ways in which such businesses can plan for tax payments such as Quarterly Payment Dates (QPDS) in line with the ZIMRA calendar.

In summation, having constant and thorough tax health checks should not be optional for any business it is therefore worth the consideration that small businesses outsource such services to the experts who understand this so you focus on what you can do best.