The administration of capital gains tax (CGT) is the machinery through which the Zimbabwe Revenue Authority (ZIMRA) turns the substantive CGT charge into collected revenue: how a seller is registered, how a disposal is declared on the Form CGT 1, how the tax is paid, how transfers are gated until the tax is settled, how third parties report disposals, and how the whole system is enforced. This lesson assembles those moving parts into a single operating picture. The governing law is the Capital Gains Tax Act [Chapter 23:01], which — rather than re-write a complete administrative code — imports the Income Tax Act (Taxes Act) [Chapter 23:06] machinery mutatis mutandis through Sections 23, 24, 27, 28 and 29, and adds CGT-specific provisions in Section 26 (payment), Sections 30A and 32 (transfer-gating) and Section 31 (third-party returns), all sitting on top of the Part IIIA withholding administration (Sections 22FA registration and 22G returns).

The declaration instrument is the Form CGT 1 — Return for Remittance of Capital Gains Tax, filed on the ZIMRA Self-Service Portal (SSP) for two asset classes only: immovable property in Zimbabwe and marketable securities. It is filed per disposal by the seller (or, in practice, by the conveyancer/estate agent acting as depositary), with prescribed supporting documents attached. A disposal that is wholly exempt under Section 10 needs no CGT 1; listed-share disposals are covered by the 1% final withholding (see Capital Gains Withholding Tax) and do not normally require a CGT 1.

The payment rule is in Section 26 of the CGT Act: tax is due no later than 30 days from the relevant accrual/transfer date (or the earlier Part IIIA withholding date). The ZIMRA CGT 1 guide refers to this 30-day rule as "Section 13", but Section 13 of the CGT Act actually deals with damage/destruction — so the operative payment provision is Section 26, and the guide's "Section 13" citation should be treated as a known mis-citation (consistent with CGT Returns and Assessments).

Registration runs on two tracks. Ordinary sellers may have no TIN until the SSP issues one as part of the CGT registration on first disposal. Separately, every person who acts as a depositary in the ordinary course of business (conveyancers, estate agents, stockbrokers, financial institutions) must register within 30 days under Section 22FA — failure being a criminal offence — and file monthly returns with the tax under Section 22G.

The keystone of CGT administration is the transfer gate. Under Sections 30A and 32, neither the Registrar of Deeds nor a company's share-transfer official may register the acquisition of a specified asset unless a ZIMRA certificate confirming the CGT has been paid is produced. No certificate, no transfer — which makes payment effectively unavoidable. The complement, from Sabeta M v Commissioner-General, ZIMRA (12-HH-079), is that ZIMRA must issue that certificate once the tax is paid. Reinforcing the gate, Section 31 requires the Registrar of Deeds (and, when not suspended, banks, building societies and brokers) to report transfers to ZIMRA — giving the Authority an independent cross-check.

Enforcement is imported: Section 27 brings in the Taxes Act offences (Sections 81–86), evidence (Sections 87–88), forms/service (Section 89) and regulations (Section 90); Section 28 imports double-tax relief (Taxes Act Section 91); and Section 29 imports the general anti-avoidance rule (Taxes Act Section 98). Penalties and interest for late or false returns flow through this imported machinery (the ZIMRA guide additionally references its own penalty sections — flagged below for verification). This lesson builds on CGT Returns and Assessments (the Section 23 assessment detail), Role of Intermediaries and Depositaries and Capital Gains Withholding Tax (the withholding/collection layer), Payment of CGT and Clearance Certificates (due dates and recovery), How to Object and Appeal a CGT Assessment (disputes), and Provisional Tax, QPDs and PAYE Administration (the parent income-tax administrative architecture it borrows).

Substantive tax law tells you whether a transaction is taxed and how much is due. Administration tells you how the State actually gets the money — the forms, registrations, deadlines, gates, reports, and penalties that convert a legal liability into cash in the Consolidated Revenue Fund. For capital gains tax this administrative layer is unusually important, because, as we saw in Capital Gains Withholding Tax, CGT falls on episodic, one-off events that are easy to ignore after the fact. A well-designed substantive charge with weak administration would collect almost nothing. Zimbabwe's CGT administration is therefore built around a single strategic idea: tie the tax to the moment of transfer, and refuse to let title pass until the tax is paid.

To see the whole machine, it helps to follow one disposal from start to finish. A seller agrees to sell a specified asset. The proceeds pass through a depositary (a conveyancer's or broker's hands), who withholds capital gains withholding tax and remits it to ZIMRA (Part IIIA — see Role of Intermediaries and Depositaries). The seller declares the disposal on a Form CGT 1 filed on the SSP, computing the final CGT and crediting the withholding (Section 22J). The tax must be paid within 30 days (Section 26). The Registrar of Deeds or the company's share registrar will not register the transfer until ZIMRA issues a certificate confirming the CGT is paid (Sections 30A/32). The Registrar separately reports the transfer to ZIMRA (Section 31), which cross-checks it against the return. If the seller fails or files falsely, the imported Taxes Act offence and penalty provisions (Section 27) and the anti-avoidance rule (Section 29) come into play. Every one of these steps is an administrative provision, and together they form an interlocking system in which evasion is genuinely difficult.

The distinctive design choice of Zimbabwean CGT administration is its reliance on borrowing. Rather than enact a full, standalone administrative code, the CGT Act imports the Income Tax Act's machinery for returns, assessments, representative taxpayers, offences, evidence, double-tax relief and anti-avoidance, applying them "mutatis mutandis" — with the necessary changes. This is efficient (no duplication) but demands care from the practitioner: to administer CGT you must read the CGT Act and the Taxes Act together, translating each imported income-tax section into its CGT context. A candidate who knows only the CGT Act will miss half the machinery; a candidate who knows the import provisions can navigate the whole system.

Why is administration so heavily examined and audited? Because it is where compliance is measured and revenue is protected. ZIMRA audit interest concentrates on the transfer gate (no certificate issued without payment), the depositary returns (the few, identifiable collection points), the currency of declaration (post-2019 USD/ZWL splits), and the per-disposal completeness of CGT 1 filing. For practitioners — especially conveyancers and estate agents who double as depositaries — administration is not background detail; it is a set of personal legal duties with criminal and civil consequences.

CGT administration is built from two layers: CGT-specific sections in the CGT Act, and imported Taxes Act sections applied mutatis mutandis.

Section 23 — returns and assessments (imported)

Section 23 of the CGT Act applies, mutatis mutandis, the following Taxes Act provisions: Section 37 (publication of notices and furnishing of returns and interim returns), Section 38 (income of minor children), Section 39 (further returns and information), Section 40 (access to public records), Sections 41–42 (shareholdings), Section 43 (submission of returns and accounts), Section 44 (production of documents and evidence on oath), Section 45 (estimated assessments), Section 46 (additional tax for default or omission, up to 100%), Section 47 (additional assessments — the 6-year/anytime-on-fraud re-opening power), Section 48 (reduced assessments and refunds), Section 49 (amended assessments of loss), Section 50 (adjustments of tax), Section 51 (assessments and recording — the notice that starts the 30-day objection clock), Section 52 (copies of assessments), Part VIIIA (information technology / e-filing, inserted by Act 12/2006), and Section 97B (calculation of interest). The detailed operation of these is the subject of CGT Returns and Assessments. Crucially, Section 37A self-assessment is NOT among the imported provisions — so CGT operates as a declaration-and-assessment system, not self-assessment.

Section 24 — representative taxpayers and agents (imported)

Section 24 imports the Taxes Act provisions on representative taxpayers (Section 53), their liability (Section 54), right to indemnity (Section 55), personal liability (Section 56), the power to appoint an agent (Section 58), the Commissioner's remedies against an agent or trustee (Section 59), the power to require information (Section 60), and public officers of companies (Section 61). This is what allows ZIMRA to look to an executor on a deceased estate, a trustee, a public officer, or an appointed agent for CGT — and it is the source of the deemed-agent duties in the Part IIIA cascade (Section 22D(5), discussed in Role of Intermediaries and Depositaries).

Section 26 — day and place for payment of tax (CGT-specific)

Section 26 (substituted by Act 16 of 2007, w.e.f. 1 January 2008) fixes when CGT is due and payable:

• (a) no later than 30 days from the date a specified asset referred to in Section 18(1) (suspensive sales) or Section 19(1) (credit sales) accrues to the taxpayer;
• (b) in any other case, no later than 30 days from the date title is formally transferred; or
• (c) no later than the last date specified under Sections 22C, 22D or 22E (the Part IIIA withholding dates) if earlier.

A proviso preserves the taxpayer's right to pay through the post, and subsection (2) allows payment at any ZIMRA branch/office or through a notified agent. The 30-day payment rule is therefore grounded in Section 26, notwithstanding the ZIMRA CGT 1 guide's reference to "Section 13" (see the verification note in section C). Interest on late foreign-currency CGT was backdated to 1 January 2020 (SI 54/2021), now SI 211/2022.

Sections 27, 28, 29 — offences, double tax, anti-avoidance (imported)

• Section 27 applies, mutatis mutandis, Taxes Act Sections 81–86 (offences), Sections 87–88 (evidence and proof), Section 89 (forms, authentication and service of documents) and Section 90 (regulations). This is the enforcement backbone of CGT — false returns, failure to file, and obstruction are offences via this import.
• Section 28 applies Taxes Act Section 91 (relief from double taxation) — relevant to cross-border disposals (see CGT on Cross-Border Asset Transfers).
• Section 29 applies Taxes Act Section 98 (the general anti-avoidance rule, GAAR) — so CGT-avoidance schemes can be reconstructed exactly as income-tax schemes are (see Transfer Pricing and Anti-Avoidance for the Section 98 framework).

Sections 30A and 32 — the transfer gate (CGT-specific)

Section 30A and Section 32 both provide that no registration of the acquisition of a specified asset on which CGT has not been withheld under Part IIIA may be executed, attested or registered by (a) the Registrar of Deeds (Deeds Registries Act [Chapter 20:05]) or (b) the person responsible for registering share transfers of a company (Companies and Other Business Entities Act [Chapter 24:31]) unless a ZIMRA certificate confirming the CGT has been paid is produced. (The source notes Section 32 is "wrongly numbered" and that Section 30A — inserted by Act 15 of 2002, with subsection (2) added by Act 1 of 2014 extending the gate to land-development stand cessions and condominium sectional titles — is the operative, fuller provision.) This gate is the practical heart of CGT administration: title cannot pass until the tax is paid.

Section 31 — third-party returns (CGT-specific)

Section 31 (inserted by the Finance Act 22 of 1999) requires, at intervals the Commissioner sets, the Registrar of Deeds to notify ZIMRA of all immovable-property transfers (with transferor/transferee names and the price). Subsection (2) requires banks, building societies and licensed brokers to notify ZIMRA whenever a marketable security is sold through them (names, nature, price) — but subsection (3) suspends subsection (2) until the Minister gazettes a date. So the Deeds-Registry reporting is live, giving ZIMRA an independent record of property transfers to match against CGT 1 filings, while the securities-reporting arm awaits activation.

Part IIIA administration — Sections 22FA and 22G (CGT-specific)

For depositaries, the administrative duties are: register within 30 days (Section 22FA, criminal offence to fail), and file monthly returns accompanied by the tax (Section 22G). These are detailed in Role of Intermediaries and Depositaries and are the administrative obligations of the collectors, distinct from the seller's CGT 1.

The ZIMRA Form CGT 1 guide — the practical layer

The Comprehensive Guide to Form CGT 1 sets out the practical administration: the CGT 1 is the Return for Remittance of Capital Gains Tax for immovable property and marketable securities; it is filed per disposal by the seller (or by the conveyancer/estate-agent depositary), on the SSP (mytaxselfservice.zimra.co.zw), with prescribed attachments; a wholly Section 10-exempt disposal needs no CGT 1; listed-share disposals under the 1% final withholding do not normally need one; the currency of the return follows Section 39A of the Finance Act (USD or ZiG per the sale); and bank-account fields are mandatory because refunds (where provisional withholding exceeded the final tax) are paid into the seller's account. The guide notes that an occasional seller with no TIN will have one issued by the SSP as part of CGT registration.

CGT administration can be understood as five functions, each answered by specific provisions.

Function 1 — Identification and registration: who is ZIMRA dealing with?

Before tax can be collected, the taxpayer must be identified. For CGT there are two registration tracks. The seller track is light: many CGT taxpayers are occasional sellers (a family selling one house) who have never filed a tax return and have no TIN. The SSP issues a TIN as part of the CGT registration when the first CGT 1 is filed — so the disposal itself triggers registration. The depositary track is heavy and mandatory: anyone acting as a depositary in the ordinary course of business must register within 30 days (Section 22FA), on pain of criminal liability, because depositaries are the recurring collection points the system depends on. The asymmetry is deliberate: occasional sellers are caught at the transfer gate regardless of prior registration, whereas the professional collectors must be pre-registered and monitored.

Function 2 — Declaration: the Form CGT 1

The declaration of a disposal is made on the Form CGT 1, filed per disposal on the SSP. The form gathers seller identification (name, ID, date of birth — which drives the over-55 PPR exemption, see CGT on Property Sales), the asset's details (address/title-deed number for property; nature and quantity for securities), the acquisition date (which determines whether the 5%-of-gross or 20%-of-gain rate applies — the 22 February 2019 threshold), the cost, improvements and selling expenses, any exemptions/rollovers claimed, and the computation of the capital gain and the tax. Two filing simplifications matter: a wholly Section 10-exempt disposal needs no CGT 1, and a listed-share disposal settled by the broker's 1% final withholding does not normally require one. Everything else — unlisted shares and all immovable property — requires a per-disposal CGT 1, even from a taxpayer who files nothing else.

Function 3 — Payment and currency: when and in what money?

CGT is due within 30 days of the relevant accrual/transfer date, or the earlier Part IIIA withholding date (Section 26). In practice, for immovable property the conveyancer withholds and remits before transfer, because Section 30A blocks registration until the tax is paid — so payment usually precedes the formal 30-day deadline. The currency of payment and of the CGT 1 follows Section 39A of the Finance Act: the tax is paid in the currency of the consideration — USD for foreign-currency sales, ZiG for ZiG sales — with mixed sales split (see Capital Gains Withholding Tax). This currency discipline is a post-2019 administrative overlay that did not exist before the multi-currency era and is a frequent source of filing error.

Function 4 — The transfer gate and third-party reporting: making payment unavoidable

The administrative genius of CGT is that it does not rely on the seller's good faith. Sections 30A/32 make the registration of transfer conditional on a ZIMRA CGT-paid certificate. Because a buyer of land is not secure until the Deeds Registry registers the transfer, and a buyer of shares is not the legal holder until the company's share registrar records it, no rational buyer will complete without the certificate — which means the seller must pay. The gate is reinforced by Section 31 third-party reporting: the Registrar of Deeds reports every property transfer to ZIMRA (names and price), giving the Authority an independent dataset to detect unreported disposals or under-declared prices. (The parallel bank/broker reporting on securities in Section 31(2) is suspended until gazetted.) And per Sabeta M, the gate cannot be weaponised against a compliant taxpayer — once the tax is paid, ZIMRA must issue the certificate.

Function 5 — Verification, assessment and enforcement: checking and compelling

Because CGT is declaration-and-assessment (Section 37A self-assessment is not imported), ZIMRA assesses the declared disposal using the imported Taxes Act machinery (Section 23): it may require further information (Section 39), production of documents on oath (Section 44), raise an estimated assessment (Section 45) where the taxpayer defaults, levy additional tax up to 100% (Section 46), re-open within 6 years (or anytime for fraud/misrepresentation/wilful non-disclosure, Section 47), and issue a reduced assessment/refund (Section 48). The assessment notice (Section 51) starts the 30-day objection clock (Section 25 → How to Object and Appeal a CGT Assessment). Enforcement of offences — false returns, failure to file, obstruction — runs through the imported Taxes Act offences (Sections 81–86) via Section 27, and avoidance schemes through the GAAR (Taxes Act Section 98) via Section 29. The administrative cycle thus closes: register → declare → pay → gate/report → verify/assess → enforce, with disputes feeding into the objection-and-appeal process and recovery into Payment of CGT and Clearance Certificates.

Why "mutatis mutandis" import matters

The repeated phrase "mutatis mutandis" ("with the necessary changes") is not boilerplate; it is an instruction to translate each income-tax provision into its CGT setting. For example, Taxes Act Section 37 speaks of annual returns of income; read into CGT via Section 23, it governs returns of capital gains on the CGT 1. Taxes Act Section 46 additional tax for understated income becomes additional tax for understated capital gain. The practitioner must perform this translation faithfully: the structure of the duty (e.g. 6-year re-opening, 100% additional tax, 30-day objection) carries across, while the subject matter shifts from income to capital gains. Getting the translation wrong — for instance, importing Section 37A self-assessment, which is not on the Section 23 list — is a classic error.

Individuals — the occasional seller and the SSP

Tafara sells his investment flat for USD 95,000 (acquired 2021 for USD 70,000, USD 5,000 costs). He has never filed a tax return and has no TIN. Administratively: his conveyancer, as depositary, withholds the provisional CGWT and remits it before transfer; the conveyancer (or Tafara) files the CGT 1 on the SSP, which issues Tafara a TIN as part of CGT registration; the gain is 95,000 − 70,000 − 5,000 − the Section 39A(9a) allowance ≈ USD 18,000-ish, final CGT at 20% (post-2019), against which the withholding is credited (Section 22J); the bank-account fields are completed so any refund reaches him; and the Deeds Registry will not register the transfer to the buyer until ZIMRA issues the Section 30A certificate. Tafara experiences CGT administration as: fill in the CGT 1, the tax comes out of the sale proceeds, and the house cannot change hands until ZIMRA is satisfied. If his flat had been his principal private residence and he were over 55 (Section 10), no CGT 1 would be required at all.

Individuals — listed shares need no CGT 1

Rudo sells ZSE-listed shares for USD 30,000. Her broker withholds 1% = USD 300 as the final tax. Administratively, she files nothing — no CGT 1, no SSP filing, no certificate process — because the listed-security withholding is final (Finance Act Section 39(a)) and the guide confirms the CGT 1 is not normally required for correctly-withheld listed-share disposals. This is the lightest administrative footprint in the whole CGT system.

SMEs and partnerships — the depositary's own compliance burden

Cornerstone Conveyancers, a law firm, handles dozens of property sales. Its administrative obligations as a depositary are heavy and personal: register within 30 days under Section 22FA (criminal offence to fail); withhold and remit within 3 working days on each sale (Section 22C); file monthly Section 22G returns accompanied by the tax; issue withholding certificates to sellers; and apply for clearance certificates (Section 22C(5)) where a seller's gain is small or exempt to avoid locking up funds. A partnership may use the joint-return facility (Section 22G(4)). For the firm, CGT administration is a continuous monthly compliance cycle, not a one-off event — and getting it wrong exposes the partners to the 15% penalty and personal liability (Section 22H).

Deceased estates and representative taxpayers — who administers the CGT when the seller cannot?

A recurring practical question is who deals with ZIMRA when the seller is not an ordinary, available individual. The answer flows from the representative-taxpayer machinery imported by Section 24 (Taxes Act Sections 53–61). On a deceased estate, the executor is the representative taxpayer: where the estate disposes of the deceased's immovable property or shares, the executor files the CGT 1 (the ZIMRA guide expressly says the form is filed "by the seller, or, where the seller is deceased, by the executor of the estate"), pays the CGT, and obtains the Section 30A certificate so the property can be transferred to the heir or purchaser. The executor's liability is the imported Section 54 liability, with a right of indemnity (Section 55) out of estate assets and personal liability (Section 56) if they distribute the estate without providing for the tax — a real trap for executors who pay legacies before settling CGT on an estate sale.

For a company, the public officer (Section 61) is the point of contact and the person answerable for the company's CGT compliance. For a trust, the trustee is the representative (and, in the Part IIIA cascade, the deemed agent under Section 22D(4)). For a taxpayer who is absent, a minor, under disability, or non-resident, ZIMRA may look to an appointed agent (Section 58) — for instance, a Zimbabwean agent of a non-resident seller of Zimbabwean land, who becomes responsible for the CGT out of funds in their control (linking to CGT on Cross-Border Asset Transfers). The administrative lesson is that CGT always has an addressable human or office behind it: executor, public officer, trustee, or appointed agent. The transfer gate (Sections 30A/32) then ensures that whoever that representative is, the tax is settled before title moves.

Large corporates and multinationals — reconciliation, currency, and audit readiness

A corporate disposing of a property portfolio must run, for each disposal, the full administrative cycle: CGT 1 on the SSP, currency-correct declaration (Section 39A USD/ZWL split), provisional withholding tracked as a prepaid tax asset, Section 22J reconciliation, and refund claims (Section 22I) where 20%-of-gain falls below the withholding. Because the Deeds Registry reports every transfer to ZIMRA (Section 31), the corporate's CGT 1 filings must reconcile to the Registry record — a mismatch (e.g. a declared price below the registered price) is a prime audit flag. Multinationals undertaking indirect/offshore transfers of mining title face the special administration of Section 30B (the Special CGT Return — see Role of Intermediaries and Depositaries and the ZIMRA Special CGT Return guide), and must be alert to the imported GAAR (Section 29) if a structure's main purpose is CGT avoidance. Audit readiness — keeping title deeds, acquisition records, improvement invoices, and currency documentation — is the practical core of corporate CGT administration, because the imported Section 47 re-opening power reaches back 6 years (or indefinitely on fraud).

Sabeta M v Commissioner-General, ZIMRA, 12-HH-079 (High Court). The defining administrative-law case for CGT: once the capital gains tax has been paid, ZIMRA is not permitted to refuse to assess and issue the certificate that permits transfer. This is the taxpayer's protection against the transfer gate (Sections 30A/32) being used to obstruct a compliant seller. Administratively, it means the certificate is a ministerial duty once payment is made, not a discretionary favour — a seller who has paid can compel issuance.

Law Society of Zimbabwe and Mollat P.M. v Minister of Finance (AG intervening), 99-SC-092 (Supreme Court). Establishes the constitutional permissibility of the withholding/clearance administration (and its limits — the pre-amendment 1998 charge was ultra vires for the 1999 gap period). For administration, it confirms that conditioning the release of funds and the registration of transfer on tax compliance is lawful when properly enacted.

Sommer Ranching (Pvt) Ltd v Commissioner of Taxes, 99-SC-065 (Supreme Court). Confirms the mutatis mutandis read-across of the Taxes Act machinery into CGT (the mechanism by which Sections 23, 24, 27–29 operate). It is the authority for treating imported income-tax assessment, agent and enforcement provisions as fully applicable to CGT with the necessary changes.

Paperhole Investments v ZIMRA, 24-HH-149 and MGZ v ZIMRA, 21-HH-269 (High Court). Drawn from the assessment context (see CGT Returns and Assessments), these confirm that an assessment must be validly made on the correct base (Paperhole) and that mis-citing the assessing authority can be fatal (MGZ) — administrative-validity principles that apply to CGT assessments raised under the imported Section 51 machinery.

A note on grounding. Much of CGT administration is procedural detail set by statute, regulation and ZIMRA practice (the CGT 1 form, the SSP, registration steps), for which there is little dedicated case law; those points rest on the CGT Act, the imported Taxes Act provisions, and the ZIMRA guide, not on judicial authority. Where the ZIMRA guide's section citations diverge from the CGT Act as read (the "Section 13" / "Sections 65–66" references), this lesson flags the divergence rather than adopting the guide's numbering uncritically.

1. Assuming CGT is self-assessed. Taxes Act Section 37A self-assessment is NOT imported by CGT Act Section 23. CGT is declaration-and-assessment — the taxpayer declares on the CGT 1 and ZIMRA assesses. Treating it as self-assessment misstates the process and the finality of the return.

2. Citing "Section 13" for the 30-day deadline. The ZIMRA CGT 1 guide says "Section 13", but the operative payment provision is Section 26; Section 13 of the CGT Act is about damage/destruction. Use Section 26.

3. Forgetting that a wholly-exempt disposal needs no CGT 1 — but a partly-taxable one does. A disposal wholly exempt under Section 10 requires no return; any taxable element requires a per-disposal CGT 1.

4. Filing one CGT 1 for multiple disposals. The CGT 1 is per disposal — one per property, one per separate unlisted-securities disposal. Bundling disposals onto one form is an administrative error.

5. Filing in the wrong currency. Under Section 39A the return and payment follow the currency of the sale (USD or ZiG); a USD sale declared in ZiG (or vice versa) is wrong and, for "purported" ZWL sales, the Section 39A(11) presumption treats them as USD at market value.

6. Treating the Section 30A certificate and the Section 22C clearance certificate as the same thing. The clearance certificate (Section 22C(5)) authorises release of funds without withholding; the Section 30A/32 certificate confirms CGT paid so the transfer can be registered. Different purposes, different stages (see Role of Intermediaries and Depositaries).

7. Depositaries failing to register (Section 22FA). Registration within 30 days is mandatory and criminal to omit; many new firms overlook it. Distinct from the seller's TIN registration.

8. Ignoring third-party reporting (Section 31). The Deeds Registry reports every transfer to ZIMRA. Under-declaring the price on the CGT 1 will not match the registered price and is a direct audit flag. (The securities-reporting arm Section 31(2) is suspended.)

9. Overlooking the 6-year re-opening power. Via imported Section 47, ZIMRA may re-open a CGT assessment for 6 years (anytime on fraud/misrepresentation/wilful non-disclosure). Discarding acquisition and improvement records after the transfer is risky.

10. Relying on the guide's "Sections 65/66" penalties. Offences and penalties are imported via Section 27 (Taxes Act Sections 81–86), not free-standing CGT Sections 65/66. Cite the imported basis.

Work through the questions one at a time. Choose an answer and it is graded immediately, with an explanation and the provision it comes from. Your progress is saved, so you can stop and resume.

• CGT administration is largely borrowed: the CGT Act imports the Taxes Act machinery mutatis mutandis — returns/assessments (Section 23), representative taxpayers/agents (Section 24), offences/evidence/forms/regs (Section 27), double-tax relief (Section 28), and the GAAR (Section 29) — so CGT must be read together with the Income Tax Act [Chapter 23:06].
• CGT is declaration-and-assessment, NOT self-assessment — Taxes Act Section 37A is deliberately not imported; the CGT 1 is a declaration that ZIMRA assesses (Section 51 notice starts the 30-day objection clock).
• The Form CGT 1 (on the SSP) is filed per disposal for immovable property and marketable securities, by the seller or the conveyancer/estate-agent depositary; wholly Section 10-exempt disposals and correctly-withheld listed shares (1% final) need no CGT 1.
• Payment is due within 30 days (Section 26) — not "Section 13" (the ZIMRA guide mis-cites; Section 13 is damage/destruction) — in the currency of the sale (Finance Act Section 39A).
• The transfer gate (Sections 30A/32) is the keystone: the Registrar of Deeds and the company share-transfer official cannot register an acquisition without a ZIMRA CGT-paid certificate; per Sabeta M 12-HH-079 ZIMRA must issue it once the tax is paid.
• Third-party reporting (Section 31): the Deeds Registry reports every property transfer to ZIMRA (live), giving an independent audit cross-check; the bank/broker securities-reporting arm (Section 31(2)) is suspended pending gazette.
• Two registration tracks: occasional sellers get a TIN via the SSP on first CGT 1; depositaries must register within 30 days (Section 22FA — criminal to fail) and file monthly returns with the tax (Section 22G).
• Verification and enforcement (imported Section 23/Section 27/Section 29): further information (Section 39), production on oath (Section 44), estimated assessment (Section 45), additional tax up to 100% (Section 46), 6-year/anytime-on-fraud re-opening (Section 47), offences (Sections 81–86), GAAR (Section 98).
• Distinguish three returns: the seller's CGT 1 (declare & pay), the depositary's Section 22G monthly return (collect & remit), and the Registrar's Section 31 notification (third-party report).
• Policy insight: CGT administration solves the "episodic tax" problem by anchoring collection to the transfer event and refusing to register title until the tax is paid — registration-gating plus third-party reporting plus imported assessment powers make a one-off, easily-evaded tax into a reliably collected one.

Table 1 — The CGT administrative provisions and their source

Table 2 — Three CGT returns compared

Table 3 — Seller registration vs depositary registration

Diagram — The CGT administrative life-cycle of a disposal

flowchart TD
 A[Disposal of a specified asset] --> B{Wholly exempt under Section 10?}
 B -->|Yes| C[No CGT 1 required]
 B -->|No| D{Listed share, 1% final withholding?}
 D -->|Yes| E[Broker withholds 1% final - no CGT 1]
 D -->|No| F[Depositary withholds and remits - Part IIIA]
 F --> G[Seller files CGT 1 on the SSP - per disposal]
 G --> H[Register / issue TIN if none]
 H --> I[Compute final CGT; credit withholding - Section 22J]
 I --> J[Pay within 30 days in currency of sale - Section 26 and Section 39A]
 J --> K{Registration of transfer needed?}
 K -->|Yes| L[Registrar / share official require ZIMRA paid certificate - Sections 30A and 32]
 K -->|No| M[Done]
 L --> N[Registrar reports transfer to ZIMRA - Section 31]
 N --> O[ZIMRA assesses and may verify - imported Section 23 and Section 47]
 O --> M

Statutes & sections

• Capital Gains Tax Act [Chapter 23:01]
• Section 22FA — registration of depositaries within 30 days (criminal offence to fail).
• Section 22G — monthly depositary returns accompanied by the tax.
• Section 23 — imports Taxes Act returns/assessment machinery (Sections 37–52, Part VIIIA, Section 97B) mutatis mutandis (note: Section 37A self-assessment NOT imported).
• Section 24 — imports Taxes Act representative-taxpayer and agent provisions (Sections 53–56, 58–61).
• Section 26 — day and place for payment: due ≤ 30 days of accrual/transfer, or earlier Part IIIA date.
• Section 27 — imports Taxes Act offences (Sections 81–86), evidence (Sections 87–88), forms/service (Section 89), regulations (Section 90).
• Section 28 — imports Taxes Act double-tax relief (Section 91).
• Section 29 — imports Taxes Act GAAR (Section 98).
• Sections 30A / 32 — transfer gate: no registration by Registrar of Deeds / share-transfer official without a ZIMRA CGT-paid certificate (Section 30A(2) extends to stand cessions and condominium sectional titles).
• Section 31 — third-party returns: Registrar of Deeds reports transfers; bank/building-society/broker securities reporting (Section 31(2)) suspended pending gazette (Section 31(3)).
• Section 13 — damage/destruction of a specified asset (NB: not the payment provision, despite the ZIMRA guide's reference).
• Income Tax Act (Taxes Act) [Chapter 23:06] — Sections 37–52 (returns/assessments), 53–61 (representative taxpayers/agents), 81–90 (offences/evidence/forms/regs), 91 (double tax), 98 (GAAR), as imported by CGT Act Sections 23, 24, 27, 28, 29.
• Finance Act [Chapter 23:04] — Section 38 (CGT rates), Section 39 (CGWT rates), Section 39A (currency of payment/return).

Case law

• Sabeta M v Commissioner-General, ZIMRA, 12-HH-079 — ZIMRA must assess and issue the CGT certificate once tax is paid (transfer-gate protection).
• Law Society of Zimbabwe and Mollat P.M. v Minister of Finance (AG intervening), 99-SC-092 — constitutionality of withholding/clearance administration and its limits.
• Sommer Ranching (Pvt) Ltd v Commissioner of Taxes, 99-SC-065 — mutatis mutandis read-across of Taxes Act machinery into CGT.
• Paperhole Investments v ZIMRA, 24-HH-149; MGZ v ZIMRA, 21-HH-269 — validity of assessments (correct base; correct authority) under the imported Section 51 machinery.

ZIMRA guidance

• Comprehensive Guide to Form CGT 1 — ZIMRA External Guide — per-disposal filing on the SSP for immovable property and marketable securities; registration/TIN issuance; currency (Section 39A); mandatory bank fields for refunds; exemptions and the listed-share final-tax position. (Guide cites "Section 13"/"Sections 65–66"; see verification note — rely on Section 26 and Section 27.)
• Comprehensive Guide to the Special CGT Return — ZIMRA External Guide — administration of the Section 30B special CGT on mining-title transfers.
• Comprehensive Guide to the ZIMRA Self-Service Portal — SSP filing mechanics.