ZIMRA's Public Notice 19 of 2026 reminds all Trusts and Trustees of their tax obligations under the Income Tax Act [Chapter 23:06], Value Added Tax Act [Chapter 23:12], and Capital Gains Tax Act [Chapter 23:01]. The Authority requires every trust to register for tax, maintain proper records, submit accurate returns, and pay all taxes due. Trusts that have not regularised their affairs by 30 April 2026 will face audits commencing in Q2 of 2026.
Core Obligations for Trusts
All trusts — whether testamentary, inter vivos, family, business, or charitable — must ensure they meet the following requirements:
- Register for tax and obtain a Taxpayer Identification Number (TIN);
- Appoint and maintain a Public Officer responsible for the trust's tax affairs as required by law;
- Submit all outstanding tax returns — income tax, VAT (where the registration threshold is met), capital gains tax;
- Fully declare all income, including rental income, business profits, investment income, and capital gains realised by the trust;
- Notify ZIMRA of any changes to business details (address, banking details, public officer, trust structure — trustees and beneficiaries, or cessation of operations) by submitting a REV 2 form to update Master Data;
- Comply with all filing and payment obligations within prescribed timeframes; and
- Maintain adequate supporting documentation for all income, expenses, and distributions to beneficiaries.
Voluntary Regularisation — Penalty Loading Model
ZIMRA is encouraging Trusts to voluntarily review and regularise their tax affairs by correcting errors, omissions, and non-declarations, submitting all outstanding returns, and settling any taxes due on or before 30 April 2026. Trusts that voluntarily disclose will have their penalties aligned to the Penalty Loading Model, which results in significantly lower penalty rates than would apply to non-compliance discovered through audit.
Audit and Enforcement — Q2 2026
ZIMRA has indicated it will institute audits on Trusts that fail to use this voluntary disclosure window, in terms of the Revenue Authority Act [Chapter 23:11] and the relevant tax laws. Non-compliance discovered through audit may result in:
- Assessments of tax owed for prior years (no statute of limitation where fraud or non-disclosure is established);
- Penalties up to 100% of the underpaid tax under the standard penalty regime;
- Interest charged from the original due date of the underpaid tax; and
- Recovery proceedings — including garnishee orders, attachment of trust assets, or court action against the trustees in their representative capacity.
Deadline: 30 April 2026. Every Trust and Trustee should register for tax (if not yet registered), update its public officer and master data records, and submit all outstanding returns. Trusts that voluntarily disclose before 30 April 2026 qualify for the Penalty Loading Model. ZIMRA audits begin in Q2 2026.