Taxation is a critical consideration for any business operating in Zimbabwe or seeking to invest in the country. For individuals, it is equally important to understand the tax implications associated with various transactions. Developing efficient tax strategies is therefore essential to support sound investment decisions and drive sustainable growth. This article provides a general overview of the tax framework in Zimbabwe.

TAXATION OVERVIEW
In Zimbabwe, the nature and the source of the income determine whether or not it is taxable. The identity and country of residence of the recipient are often irrelevant. Thus, generally, all receipts (not of a capital nature) arising from a source within Zimbabwe are taxed, irrespective of the residential status of the taxpayer. Income arising from sources outside Zimbabwe is taxable only if its source is “deemed” by the legislation to be within Zimbabwe.

Since the Income Tax Act [Chapter 23:06] does not define the “source”, guidance on the subject is derived from case law. In CIR v Lever Bros and Unilever Ltd (1946) the applicable principle was that the source of receipts, received as income, is not where they come from but the originating cause of their being received as income is the work which the taxpayer does to earn them.

The principle laid down in the Lever Bros and Unilever Ltd case provides the starting point for determining the source of income in Zimbabwe. It establishes that the work undertaken by a taxpayer may constitute a business carried on, an enterprise pursued, or any activity in which the taxpayer engages. Such work may take the form of personal exertion whether mental or physical or it may arise from the employment of capital, either through its active use to generate income or through allowing another to use it for consideration. In many instances, income is produced through a combination of these elements.

One notable aspect in this regard though, is that the matter of whether receipts are remitted to Zimbabwe or not, is not relevant, thus making a taxpayer liable even for offshore receipts.

In determining the source of income in Zimbabwe, one would require to interpret and rely on the deeming provisions of the main statutes governing tax administration, Double taxation Agreements (DTAs) and Case law. The Zimbabwe Revenue Authority is mandated at enforcing the provisions of the tax statutes.

Key statutes governing tax administration
(a) Finance Act Chapter  23:04
(b) Revenue Authority Act Chapter 23:11
(c) Income Tax Act Chapter 23:06
(d) Value Added Tax Chapter 23:12
(e) Capital Gains Tax Act Chapter 23:01
(f) Customs & Excise Act Chapter 23:02
(g) Stamp Duties Act Chapter 23:09
(h) Estate Duty Act Chapter 23:03

INCOME TAX

What is Income Tax?

It is Tax on Taxable Income

A distinction should be drawn between “Taxable income from employment” and “Taxable income from trade or investments”

Taxable income from employment – means any part of the taxable income of a person other than a company, trust or a pension fund, which consists of remuneration as defined in the 13th Schedule of the Taxes Act. 3% Aids levy is chargeable except in cases specified under section 14(5) of the Finance Act.

Taxable income from trade or investments – means any part of the taxable income of a person other than a company, trust or pension fund, which is received by or accrues to him from any trade, investment or other activity, but does not include taxable income from employment. It is taxed at 25% plus 3% Aids levy (25.75%)

Zimbabwe presently operates a source-based tax system. This means that income arising from a source within Zimbabwe, or deemed to be within Zimbabwe, is subject to taxation in Zimbabwe unless a specific statutory exemption applies. Each transaction must therefore be considered on its specific facts to determine whether it gives rise to taxable income in Zimbabwe.

Income earned by foreign companies from a source within, or deemed to be within, Zimbabwe is likewise subject to tax in Zimbabwe. Where such income is generated, it becomes necessary to determine whether the foreign company is required to register a local entity or establish a taxable presence in Zimbabwe.

The applicable corporate tax rates and the rates applicable to individual income from trade and investment are set out in the table below:

EMPLOYMENT TAX

Employment income is income that accrues to an individual from rendering services within or deemed source within Zimbabwe. An employer-employee relationship should exist. The employment rules also cover a person’s relationship with past and prospective employers.

Taxation basis of employees

Services rendered in Zimbabwe

As stated above taxation in Zimbabwe is based on source principle and not on the residence status of a person. It was established in the case of Commissioner of Taxes vs Shein  22 SATC 12 that the source of income for services rendered is the place where the services would have been rendered or performed

This means that residents and non-residents rendering services in Zimbabwe, no matter where the payment is coming from are liable to employees’ tax in Zimbabwe on such services.

Services rendered in pursuance of Zimbabwean Trade

Income for services rendered outside Zimbabwe may not escape taxation in Zimbabwe notwithstanding the fact that the person has rendered services outside Zimbabwe for a period exceeding 183 days. If the services are rendered by resident in pursuance of trade carried on in Zimbabwe, the income connected to those services shall be deemed to be from a source within Zimbabwe no matter the duration the services are rendered outside Zimbabwe (section 12 (1) (b)).

PAYE Remittance
Employees‘ tax should be remitted to ZIMRA by the 10th day of the month following the month of deduction, or within such other period as the Commissioner may for good cause allow. If a person has ceased to be an employer before the end of such month, the tax should be remitted the next day after he ceases to be an employer. Payment should be accompanied by a return (Form P2). If tax is not remitted on time 100% penalty and interest of 25% p.a. accrues.

The Commissioner has the right to sue for any outstanding taxes together with penalty and interest and he may recovery them through an action by him in any court of competent jurisdiction or by garnishing of the employer‘s bank accounts.

The employer should also act on the directive of the Commissioner regarding how much tax should be deducted in certain instances e.g. the Commissioner often issue a tax directive for items like pension income, gratuity and retrenchment package.

NSSA Contributions
NSSA contributions are a form of social security meant to cushion the employee in the event of injury or disablement at work. It is prescribed in terms of the National Social Security Act (Chapter 17:04). NSSA rules require employers and employees to make a 50/50 contribution to NSSA, each contributing 3.5% of the employee‘s basic salary.

INVESTMENT INCOME
Investment income normally comprises of interest and dividends. Zimbabwe treats the Withholding Tax (WHT) deducted from investment income as a final tax; consequently, there is no need to declare this type of income on tax returns or to pay any additional tax.

Dividend income
‘Dividends’ means “any amount distributed by a company … to its shareholders…”. The WHT on dividends is at a rate of 15%, non-residents shareholders at a rate of 15%,  except in the case of distributions made from companies that are listed on the Zimbabwe Stock Exchange, where a lower rate of 10% is applicable.

In Zimbabwe, the Income Tax Act (Chapter 23:06) governs the taxation of dividends. Dividend income is the profit distribution made by a corporation to its shareholders and they are taxable if they arise from a Zimbabwean company, regardless of shareholder’s residence. However, Double Taxation Agreements (DTAs) may reduce or exempt WHT for non-resident shareholders depending on treaty terms.

Section 80 of the ITA governs the WHT.WHT (Withholding Tax) on dividends is necessary to ensure efficient collection of tax and prevent tax evasion. It requires companies to withhold a portion of the dividend payment and remit it directly to the tax authority. This ensures that the government receives its share of tax revenue promptly.

WHT on dividends is necessary to ensure that the government collects tax on the income earned by shareholders. It helps prevent tax evasion and promotes early tax collection because dividends are paid out periodically and collecting tax at the source (from the company) is more efficient than collecting from individual shareholders.

These may be divided into the following (briefly):

• Resident shareholder’s Tax
• Non- resident shareholders tax
• Non- resident tax on royalties
• Non- executive director’s fees

Interest income
Interest arising in the name of Zimbabwe residents from ’financial institutions normally has a WHT of 15% deducted by the institution before it is paid to the investor. Non-resident financial institutions are exempt from this WHT for encouragement of foreign investments. Interest arising from sources other than ’financial institutions’ is subject to tax at the corporate tax rate (25%+3% AIDS levy).

Interest income from banks, building societies, licensed financial institutions is subject to WHT at 15%, which is treated as a final tax for residents. Non-residents are exempted from this WHT unless specified by a treaty. Interest earned offshore is generally not taxable, unless deemed to arise from Zimbabwe under statutory provision or DTAs.

Allowable Deductions
Section 15 (2) the Act makes provisions for specific allowable deductions. Some of the deductions development and exploration costs. These deductions reduce a taxpayer’s gross income to arrive at taxable income. To qualify expenses must be incurred in the production of income or for the purpose of trade, and must not be of a capital nature, unless specifically allowed.

In mining and energy policies, exploration and development costs are deductible. Special initial allowance is at 50% in one year, 25% in each of the next two years (for SEZ or solar projects). In Agricultural Contracts, inputs, transport, and extension services may be deductible if tied to income generation.

WEALTH TAX
The Finance Act, 2023 amended the Income Tax Act [Chapter 23:06] to insert a new section 36O which provides for the Wealth Tax. The wealth tax is a tax based on the value of an asset owned by a taxpayer.The Finance Act, 2023 amends the Income Tax Act [Chapter 23:06] to insert a new section 36O which provides for the Wealth Tax chargeable on a taxable dwelling whose value exceeds two hundred and fifty United States Dollars (US$250 000.);

The Wealth Tax chargeable in terms of section 36O of the Taxes
Act shall be calculated at the rate of one per centum of the value of a
dwelling other than a principal private residence, if such value exceeds
two hundred and fifty thousand United States dollars:’

The wealth tax is a tax on an owner of a dwelling as defined in the Income tax Act.

Properties on which the tax is chargeable
Subsection (1) of section^[1] 36O defines a “dwelling” as a building or any part of a building, which is wholly or mainly used for the purpose of residential accommodation. What this means is that in this section, every time the word “dwelling” is used it excludes a building used for commercial, industrial or agricultural purposes. A taxable dwelling means any dwelling the rateable value of which exceeds two hundred and fifty thousand United States dollars in the year of assessment concerned. The tax applies to non-primary residences, meaning principal private residences are exempted.

The Wealth Tax is calculated at 1% of the value of the taxable dwelling. The valuation of the property is to be done by the local authority in which the property is located and is conducted in the manner prescribed in Part XVIII of Urban Councils Act [Chapter 29:15].

VALUE ADDED TAX

What is VAT?
Value Added Tax (VAT) is an indirect tax on consumption, charged on the supply of taxable goods and services. It is levied on transactions and also on the importation of goods and services. The principal legislation is the Value Added Tax Act (Chapter 23:12) supported by the Finance Act (Chapter 23:04). VAT is collected by registered operators and remitted to the Zimbabwe Revenue Authority (ZIMRA).

What is the General Rate of VAT?

With effect from the 1^st of January 2023 the standard VAT rate in Zimbabwe is 15%. Section 17 of the Finance (No.2) Act, 2022 which was gazetted on the 30th of December 2022 provides as follows;

The rate of value added tax in respect of—
(a) goods or services supplied by any registered operator in the course or furtherance of any trade carried on by the registered operator; and
(b) the importation of any goods into Zimbabwe by any person; and
(c) the supply of any imported services by any person; and
(d) goods and services sold through an auctioneer (as defined in section

56(6)) of the Value Added Tax Act [Chapter 23:12] by persons who are not registered operators;

shall be fifteen per centum.

Generally, all goods and services are standard rated unless specifically exempted, zero-rated or subject to VAT at a special rate.

i    Zero-rate (0%)
Exports of goods from Zimbabwe to any address in an export country.
Basic foodstuffs such as sugar.

ii    No value added tax is chargeable on exempt supplies.^[2]
Examples of exempt supplies include:

(a) Financial services.
(b) Provision of electricity for domestic use.
(c) The supply of any medical services by any person or institution;
(d) Rates charged by Local Authorities.

Businesses earning over USD25,000 annually must register for VAT. Entities submitting tenders above USD25,000 are automatically registered. VAT returns and payments are now due by the 15^th  of the following month.

Value Added Tax on Betting and Gaming
The rate of value added tax in respect of transactions or receipts on betting and gaming as set out in the table in Part 11 of section 17 of the Finance (No.2) Act,2022 is generally 15%.

General Rate of Value Added Tax on Supply of Cellular Telecommunications Service^[1]. The rate of value added tax in respect of the supply of cellular telecommunications services in the course of furtherance of the supply of such service by a registered operator is 15%.

Value added tax on imported services
Services imported by any person, whether a registered operator or non-registered individual or company are subject to VAT under Section 6 (1) c of the VAT Act. The supplier must be a non-resident, and the services should be consumed or utilized in Zimbabwe.

Imported services like those ordinarily zero-rated or exempted by local suppliers are exempted from VAT for instance actuary, insurance, medical services, financial guarantee or suretyship.
Time of supply rule for imported services:

VAT on imported services must be remitted to ZIMRA by the 15^th of month following the invoice, payment or service rendering. Thus, the time of supply is determined by the earliest of the time of the invoice, payment, or service rendered.

Value of supply for imported goods:
The value of imported goods is either the consideration determined by section 9 (3) of the VAT act or the open market value, whichever is greater. ZIMRA typically applies 15% on the consideration.

CUSTOMS DUTY
Customs and Excise Duty is administered in terms of the Customs and Excise Act [Chapter 23:02]. Tariff classification, valuation and origin are core customs compliance procedures and the main pillars for establishing liability for duties and VAT on imported goods. Imported and exported commodities need to be classified according to an appropriate tariff heading. The tariff classification code is directly linked to the rate of duty payable on that commodity. In Zimbabwe the general rate of Customs duty on imported goods ranges between 0%-40% . However, depending on the imported commodity, preferential rates of duty may be applicable and the Tariff Handbook provides detailed codes and rates for each commodity.  

Zimbabwe is a signatory to a number of trade agreements with different countries which it confers preferential rate of duties on imported commodities from such countries (when accompanied with the relevant proof of origin). Most notable are the following agreements:

(a) COMESA ( Consisting of African countries)
(b) SADC (Consisting of African countries)
(c) AfCFTA (consisting of African Countries).

Excise Duty is levied on certain locally manufactured goods, (certain luxury or non-essential items) and this is administered under the Excise Tariff.

Because ZIMRA is in the position to control and prevent the importation or exportation of commodities, it acts as an agent on behalf of numerous other government institutions or organizations to ensure that commodities, in terms of other legislation, are not imported or exported illegally when it is a requirement from other departments or institutions that permits must be issued. Therefore, it should also be noted that certain commodities will require valid permits before they are imported or exported. Examples include: pharmaceuticals, agricultural inputs, and electrical equipment. Failure to produce permits may result in seizure, penalties, or delayed clearance.

CAPITAL GAINS TAX
Capital Gains Tax (CGT) is an amount levied on the capital gain arising from the disposal of a specified asset in terms of section 6 of the Capital Gains Tax Act [Chapter 23:01]. Specified assets mean immovable property (land and buildings) and any marketable security (debentures, shares, unit trusts, bonds, intellectual property). Valuations for purposes of determining the values of the assets will also be required by the taxing authority (ZIMRA), together with proof of payment for the property (if case of a sale).

Rates of Capital Gains Tax
The table below summarizes the CGT rates as provided for in terms of the Finance Act (Chapter 23:04):

The Seller of a specified asset has the obligation to pay Capital Gains Tax when disposing of a property. However, the Seller may be exempted from paying Capital Gains Tax in certain specified instances. Some of the exemptions are set out below;

(a) Where the property is the primary residence and the seller is over the age 55.
(b) Inheritance and deceased estates distributions.
(c) Transfers of any specified assets between spouses.
(d) Transfer of principal private residence between former spouses following a divorce order.

SPECIAL CAPITAL GAINS TAX
The Capital Gains Tax Act [Chapter 23:01] was amended by the Finance Act, 2023 by the insertion of section 30B which provides for a 20% special capital gains tax chargeable on entities acquiring mining title or any interest therein. The tax shall be chargeable on the value of the transaction. Further the tax applies to a transaction involving the transfer of a mining title acquired within the ten years prior to the 1st of January 2024 or that acquired on or any time after the 1st of January 2024.

SCGT applies to direct transfers of mining titles, transfers of shares or interests in companies that own or control mining titles. They also apply to transfer between beneficial owners and nominees and any person or entity with s stake or interest in a mining title. The seller must submit a standard CGT return. The buyer/transferee must file a Special CGT via ZIMRA’s TaRMS portal including transaction value and currency, full details of the mining title, and names and addresses of both parties.

The special capital gains tax shall be paid in United States Dollars or any other foreign currency at the rate of twenty percent of the total value of the transaction unless the transfer is subject to special approvals by the Minister.

The tax is to be paid no later than the 1st of April 2024 for mining titles acquired prior to 1 January 2024. For mining titles acquired on or after the 1st of January 2024, the tax is to be paid within thirty days after the transaction is concluded. No transfer of a mining title shall be registered unless the special capital gains tax has been paid.

STAMP DUTY ( TAX ON PROPERTY PURCHASE)
In Zimbabwe, stamp duty is payable on the registration of title upon acquisition of immovable property. The Stamp duty is calculated in accordance with the Schedule to Chapter II of the Finance Act [Chapter 23:04] as read with the Stamp Duties Act [Chapter 23:09].

In terms of the Stamp Duties Act, stamp duty is calculated using the declared value of the property or the consideration payable as at the date of acquisition of immovable property. The date of acquisition is also defined as the date on which the transaction was entered into or the date on which the person who acquired the property became entitled to it. In other words, stamp duty is charged on the current fair market value of the property or the purchase price.

The Registrar of Deeds will require declarations from both parties to the transaction indicating the value of the property and the improvements thereon and this is to ensure that the adequate and appropriate duty is paid.

The Stamp duty calculations in terms of the Schedule to Chapter II of the Finance Act [Chapter 23:04] are currently laid out as follows;

1. For example, calculation of stamp duty payable on acquisition of property valued at $4 000.00

Duty is                                    = 1% *(5000- 4000) + 70

                                                      =1%( 1000 )+ 70

                                                      =$80.00

2. Calculation of stamp duty payable on acquisition of property valued at $50 000.00

Duty is                           = 3% * ($50 000.00 – 20 000.00) + 370

                                                      = (3% * 30 000.00) + 370

                                                      = 900 + 370

                                                      = $1 270.00

3. Calculation of stamp duty payable on acquisition of property valued at $120 000.00

Duty is                           = 4% * (120 000.00 – 100 000.00) + 2 770.00

                                             = (4% * 20 000.00) + 2 770.00

                                             = 800 + 2 770.00

                                             = $3 570.00

The law places exemptions from payment of stamp duty on registration of an acquisition of immovable property in certain circumstances which are listed in item 5 to the Schedule to Chapter II of the Finance Act, which include the following;

(a) Property acquired by way of inheritance
(b) Property acquired in terms of a divorce order
(c) Property acquired by an ecclesiastical, charitable or educational body which is recognized by the Government as being of a public character as approved by the Minister
(d) A joint owner of property who acquires sole ownership in the whole property
(e) Registration of a correction of an error in the registration of the acquisition of property where the stamp duty had already been paid
(f) Property acquired by a local authority from the State through a transaction not involving purchase and sale

DECEASED ESTATES TAXES

Masters Fees
All deceased estates are liable to pay a tax of 4% of the value of the Estate to the Master of High Court. Normally, the estate should be able to cater for its own expenses. However, if the estate lacks sufficient liquidity, beneficiaries may contribute funds to avoid the sale of assets. The fees applies regardless of whether the estate is liable for estate duty making it a baseline cost in all estate administration.

Estate Duty Tax
It is the tax charged on the value of estates exceeding a certain amount as may be gazetted and is currently set at USD100,000.


HOW IS ESTATE DUTY CALCULATED?
Total Assets subtract Total Liabilities subtract Principal residence subtract Family Car Subtract Rebate = Dutiable Amount

5% of the Dutiable amount is the estate duty payable.

This tax is payable to ZIMRA is meant to capture wealth transfer upon death. Estates below the threshold are exempt from estate duty but still subject to Master’s fees.

Income earned by the deceased before death but received afterwards is taxable in the hands of the estate and this include rental income, dividends, or business proceeds. The nature of the income does not change due to death; executor must declare such income in the estate’s tax return. Income accruing directly to beneficiaries after death may also be taxable depending on its source and nature and should be settled before distributing assets.

MINING TAX
The taxable income of mining operations follow the same principle as other business activities, with some exceptions. Mining operators are subject to Income Tax Act’s provisions and can claim allowances and deductions unless specifically prohibited.

Scope of mining tax:
Mining taxable income that is derived from the mining operations and is computed similarly to other business. Miners are entitled to specific capital allowances like capital redemption allowance instead of SIA and wear and tear. Other differences include deduction of prospecting operation expenditure, recoupment calculation methods and indefinite carrying forward of assessed losses.

Determination of Royalty
Section 244 of the Mines and Minerals Act (Chapter 21:05) provides for the collection of mineral royalty on all minerals or mineral-bearing products derived from a mine location whether or not the minerals are sold within or outside Zimbabwe.

Royalty Calculation
The royalties chargeable under section 36Q of the Taxes Act will be determined according to the provisions in Chapter VII of the Taxes Act.

Registration of Mining Entities and Acquisition of Mining Titles (Section 98D)

Mandatory Registration for Mining Entities
From 1st January 2025, mining entities (whether local or foreign) will not be able to acquire or transfer mining titles unless they are registered taxpayers with the Zimbabwe Revenue Authority (ZIMRA). This ensures that mining entities are in compliance with tax obligations before being granted or transferring mining rights.

Mining Title Definition
The definition of “mining title” includes mining claims, leases, and special grants as well as any share, stake, or interest in a mining title.

Certificate Requirement for Mining Title Registration
When acquiring or transferring a mining title, the mining entity must submit a tax registration certificate issued by ZIMRA. If this certificate is not provided, the transaction will be deemed void and can be cancelled at the request of the Commissioner-General.

Definition of “Beneficial Owner” and “Controller”

Clarification on Ownership and Control
The Act expands the definitions of beneficial owner and controller to include entities or individuals who exercise significant control over a mining entity, either directly or indirectly. A controller is defined as a person who, despite formal structures, has significant influence over the affairs of the entity, such as through a substantial stake or decision-making power.

This ensures that not just the formal titleholder but also those with real control or beneficial interest in a mining operation are captured under the tax and regulatory framework.


Amendments to the Income Tax Act [23:04]: Inclusion of Mining Royalties (Section 36Q and Thirty-Seventh Schedule):
New Section 36Q – The Income Tax Act was amended by the insertion of a new section 36Q which provides for the charging, levying and collection of mining royalties throughout Zimbabwe and the Thirty-Seventh Schedule outlines how these royalties will be assessed and collected. The inclusion of mining royalties under the Act means that mining companies must account for this additional tax in their financial operations.


New Thirty-Seventh Schedule – This schedule provides a framework for calculating, declaring, and paying mining royalties in Zimbabwe, detailing responsibilities, rates, and penalties. Key provisions include:

Definitions

Liable Person
– Miners required to submit royalty returns.
– Fidelity Gold Refinery (Private) Limited when withholding royalties.
– Mineral: As defined in Section 36(f) of the Finance Act [Chapter 23:04].


Royalty Calculation
Criteria for Different Minerals:


Platinum Group Metals:
Based on the London Metal Exchange price:
– 85% for concentrate.
– 90% for matte.

Gold:
Gross fair market value set by Fidelity Gold Refinery.

Diamonds and Other Minerals:
Value determined by contracts with the Minerals Marketing Corporation of Zimbabwe.
Gross value excludes costs like beneficiation or processing.

Declaration and Payment
Submission Deadlines
Returns must be submitted by the 10th day of the month following the disposal of minerals.

Returns are treated as self-assessments for royalties due.

Commissioner’s Role:
Can extend deadlines or raise additional assessments if returns are incomplete or inaccurate.

Penalties for Non-Compliance

Default Penalties:
– Double the royalties or a fine for missing deadlines.
– Additional royalties for omissions, incorrect statements, or undisclosed facts.

Remission:
Penalties may be waived if non-compliance was not intentional.

Royalty Collection

Deduction at Source:
Agents like financial institutions or authorized entities must deduct royalties for certain minerals.

Payment Breakdown:

For gold, diamonds, platinum, and similar minerals:
– 50% in-kind (physical mineral).
– 10% in foreign currency.
– 40% in local currency.

For other minerals:
– 50% in foreign currency, 50% in local currency.

Late Payment Penalties:
Interest accrues on unpaid royalties.
Persistent non-compliance results in fines or imprisonment.

Commissioner’s Powers
May estimate royalties if returns are missing or unsatisfactory.
Can recover unpaid royalties and penalties as civil debts

Recent amendments:

Amendment to Section 30B of the Capital Gains Tax Act [Chapter 23:01]
The Capital Gains Tax Act [Chapter 23:01] is amended in section 30B, titled “Special capital gains tax on entities acquiring mining title or any interest therein,” through the repeal of subsection (3) and its replacement with the following provision:

“ A special capital gains tax shall be levied and charged on the transfer of a mining title, being a tax on the value of any transaction concluded within or outside Zimbabwe, whereby any mining title has been transferred to an entity, provided that such transfer occurs on or after the 31st December, 2023.”

This amendment clarifies the applicability of the special capital gains tax to all transactions involving the transfer of mining titles, irrespective of the jurisdiction in which such transactions are executed, provided the transfer occurs after the stipulated date.

Amendment of the Finance Act [Chapter 23:04]
Section 36 of the Finance Act [Chapter 23:04] is amended by the addition of paragraph (f) after paragraph (e).

The amendment expands the definition of “mineral” to include mineral ore and mineral-bearing products. It also grants the Minister, in consultation with the Minister of Mining, the authority to classify additional naturally occurring substances as minerals through statutory instruments. This ensures flexibility in addressing emerging resources or substances of economic value.

Sections 37A and 37B of the Finance Act are repealed.

The Schedule to Chapter VII of the Finance Act [Chapter 23:04] is amended, with effect from the 1st of January, 2025, in the section prescribing the rates of royalties for the purposes of section 245 of the Mines and Minerals Act [Chapter 21:05], by the deletion of the items referring to “Coal” and “Black granite and other cut or uncut dimensional stone” and the substitution thereof with the following items:
– All types of coal . . . . . . . . . . . . . . 2
– Black granite . . . . . . . . . . . . . . . 2
– Other cut or uncut dimensional stone . . . . . . . . 2
– Quarry stones . . . . . . . . . . . . . . . 2


This amendment establishes a uniform royalty rate of 2% for the specified minerals and mineral products
Zimbabwe’s tax framework is a comprehensive system built on the source-based principle, taxing income that arises within or is deemed to arise within the country. The various tax heads range from Income Tax, PAYE and VAT to Wealth Tax, Capital Gains Tax, Mining Royalties, Customs Duty, Stamp Duty and Estate Taxes . A proper understanding of Zimbabwe’s tax laws is therefore essential for ensuring compliance, optimising tax efficiency, and supporting sound financial decision-making.

For assistance on this or any other tax-related matter, please contact our Tax Practice Group on info@mmmlawfirm.co.zw .

[1] Part III of Section 17 of the Finance Act (No.2) Act,2022

[1]  Income Tax Act

[2] Section 11 of the Act.