ZIMRA's Public Notice 24 of 2026 reminds all local entities and taxpayers of their tax obligations regarding payments made to non-residents in terms of the Income Tax Act and the Value Added Tax Act. Local payers are required to withhold and remit tax on a defined list of foreign payments, and ZIMRA has indicated it will commence audits of non-compliant payers after the 30 April 2026 regularisation deadline.
Foreign Payments That Trigger Tax in Zimbabwe
Tax is payable on foreign payments made in respect of:
- Royalties — including payments for the use of patents, trademarks, copyrights, software, and similar intellectual property;
- Dividends — declared and paid to non-resident shareholders;
- Management Fees — for management services provided by a non-resident parent or affiliate;
- Professional Fees — consulting, legal, technical, and other professional services rendered by non-residents; and
- Imported Services — services rendered by a non-resident to a Zimbabwean recipient (subject to VAT on imported services in addition to applicable income tax withholding).
Each category attracts withholding at the prescribed statutory rate, subject to relief under any applicable Double Taxation Agreement (DTA). The local payer is the agent of the Commissioner for the withholding obligation — meaning the liability for the unwithheld tax shifts onto the Zimbabwean payer if the withholding is omitted.
Call to Regularise — Deadline 30 April 2026
ZIMRA urges all taxpayers who have made payments to non-residents to immediately review all such payments and regularise their tax affairs by:
- Correcting errors, omissions, and non-declarations in prior withholding tax returns;
- Submitting all outstanding withholding tax returns for the affected payments; and
- Settling any taxes due on or before 30 April 2026.
Reviewing prior payments is best done by reconciling the payables ledger against withholding tax returns lodged for each year — particularly for management and professional fees paid to related foreign parties, where omissions are most common.
Audit and Enforcement — What to Expect After 30 April
ZIMRA has indicated it will institute audits on local entities and taxpayers that fail to take this regularisation opportunity, in terms of the Revenue Authority Act [Chapter 23:11] and the relevant tax laws. Outcomes of an audit may include:
- Assessments of withholding tax for the periods reviewed (often back-dated multiple years);
- Penalties applied to the unwithheld and unremitted amounts;
- Interest from the original due date of remittance; and
- Recovery proceedings against the payer's assets and bank accounts.
Deadline: 30 April 2026. Review every payment your business has made to a non-resident — royalties, dividends, management fees, professional fees, and imported services — and lodge all outstanding withholding returns and remit the underlying tax. Where a DTA applies, ensure the correct reduced rate is documented. Audits begin after the deadline.