A tax is only as effective as the machinery that compels its payment. The Capital Gains Tax Act [Chapter 23:01] does not build a free-standing enforcement code; instead, through a series of "application" provisions, it imports the enforcement architecture of the Income Tax Act [Chapter 23:06] (the "Taxes Act") and applies it mutatis mutandis to capital gains. The result is a layered enforcement system resting on five pillars: assessment and additional-tax powers, interest on unpaid tax, recovery powers (including third-party collection), criminal offences and evidentiary rules, and a uniquely powerful registration chokepoint that makes payment a precondition of transferring title.

The backbone is Section 23, which applies the Taxes Act's returns-and-assessments provisions — including Section 45 (estimated/best-judgement assessments), Section 46 (additional tax for default or omission), Section 47 (additional assessments) and Section 97B (interest) — to CGT. Section 26 (day and place for payment) fixes the due date: tax is due and payable no later than 30 days from the date the relevant amount accrues (suspensive sales, Section 18(1)/19(1)) or from the date title is formally transferred, with interest running on late payment at a rate fixed by the Minister, and — critically — Section 26(4) gives the Commissioner the same recovery powers for CGT as the Taxes Act confers for income tax. Section 24 imports the representative-taxpayer and agent provisions (Taxes Act Sections 53–61), including the power to appoint an agent (the garnishee mechanism, Section 58) and to pursue public officers of companies (Section 61). Section 27 imports the Taxes Act's offences (Sections 81–86), evidence and proof (Sections 87–88), and forms/service (Section 89) provisions, so failure to comply with CGT obligations is a criminal matter, not merely a civil debt.

For the withholding stream (Part IIIA), the Act supplies its own penalty. Section 22H makes a depositary or agent who fails to withhold or remit capital gains withholding tax personally liable for the tax plus a further amount equal to 15% of the tax that should have been withheld, with a discretionary waiver of the 15% where the Commissioner is satisfied there was no intent to evade. Section 22G obliges depositaries to furnish returns.

The most distinctive enforcement device is the clearance-certificate chokepoint. Under Section 30A (and the duplicated Section 32), no registration of an acquisition of a specified asset may be executed by the Registrar of Deeds or the share-transfer registrar unless a ZIMRA certificate confirms the CGT has been paid. Title simply cannot pass without engaging ZIMRA — a self-enforcing mechanism that the courts have confirmed cuts both ways: in Sabeta v Commissioner-General: ZIMRA 12-HH-079, ZIMRA was held not permitted to refuse to assess and issue a certificate once the tax is paid, and in Sibanda v Masanga 24-SC-090, a clearance dispute over fair market value stalled a transfer. Detection is reinforced by Section 31, which compels the Registrar of Deeds, banks, building societies and stockbrokers to report transfers of immovable property and marketable securities to the Commissioner — a third-party information net that makes undisclosed disposals hard to hide.

Enforcement is bounded by the taxpayer's rights: Section 25 preserves the 30-day right of objection against assessments and listed decisions, with appeal under the imported Taxes Act provisions (Sections 62–70), and Section 22I caps refund claims at 6 years. The constitutional limits of the withholding regime were tested in Law Society of Zimbabwe & Mollat v Minister of Finance 99-SC-092. This lesson dissects each enforcement pillar clause by clause, works the penalty and interest computations in USD, and maps how ZIMRA moves from a missed deadline to a fully enforced collection.

Enforcement is the set of legal powers by which the State compels the assessment, payment and, where necessary, forced recovery of a tax, and punishes non-compliance. A capital gains tax is peculiarly vulnerable without strong enforcement for three reasons. First, disposals are episodic and often private — a person may sell a single piece of land once in a decade, with no employer or PAYE system withholding tax at source, so the State depends heavily on the taxpayer's own honesty unless it builds in detection. Second, the sums are large and lumpy — a property or share sale can generate a substantial one-off gain, creating both the incentive to conceal and the cash to litigate. Third, valuation is contestable — because Section 8(2)(b) deems non-sale disposals to occur at fair market price, and Section 14 lets the Commissioner substitute market value, enforcement turns on contested valuations that taxpayers have every reason to depress.

Zimbabwe's answer is to graft CGT enforcement onto the mature enforcement code of the Income Tax Act, rather than reinventing it, and then to add two CGT-specific devices that suit the asset-transfer context: a withholding system (Part IIIA, with its own 15% penalty in Section 22H) that collects tax before the seller receives the proceeds, and a registration chokepoint (Section 30A) that makes payment a precondition of title. Together these convert CGT from a tax that relies on voluntary disclosure into one that is substantially self-enforcing at the point of transfer.

This lesson sits in the administrative cluster of the CGT chapter, alongside Returns and Assessments, Objections and Appeals, Payment and Recovery, and Withholding Tax on CGT. It draws those threads together under the single theme of how the State makes CGT stick. It is examinable because candidates must distinguish penalty from interest from additional tax, know who can be made liable (the taxpayer, the representative taxpayer, the depositary/agent, the appointed third-party agent), and understand the registration and reporting mechanics that ZIMRA actually uses. It is a high ZIMRA-audit-interest area precisely because the chokepoint and third-party reporting give the Authority hard data to test against returns.

The defining feature of CGT enforcement is that the Act works by cross-application. Each provision below was confirmed against the Capital Gains Tax Act as at 27 May 2025.

Section 23 — returns and assessments (the assessment engine)

Section 23 applies, mutatis mutandis, a long list of Taxes Act provisions "for the purposes of providing for and giving effect to" returns and assessments under the CGT Act. The enforcement-critical members of that list are:

• Section 37 — publication of notices about, and furnishing of, returns and interim returns;
• Section 39 — furnishing of further returns and information;
• Section 40 — the Commissioner's access to public records;
• Sections 41 and 42 — shareholdings information;
• Section 43 — submission of returns and preparation of accounts;
• Section 44 — production of documents and evidence on oath (the inquiry power);
• Section 45 — estimated assessments (the Commissioner may assess to the best of his judgement where no return, or an unsatisfactory return, is filed);
• Section 46 — additional tax in the event of default or omission (a punitive uplift on the tax);
• Section 47 — additional assessments (re-opening an under-assessment);
• Section 48 — reduced assessments and refunds;
• Section 49 — amended assessments of loss;
• Section 50 — adjustments of tax;
• Section 51 — assessments and the recording thereof; Section 52 — copies of assessments;
• Part VIIIA — information technology for the Taxes Act (e-filing);
• Section 97B — calculation of interest payable.

The practical upshot: non-filing or under-declaring CGT exposes the taxpayer to an estimated assessment (Section 45), an additional-tax penalty (Section 46), interest (Section 97B), and the Commissioner's documentary-inquiry powers (Section 44) — all borrowed wholesale from the income-tax regime.

Section 24 — representative taxpayers and agents (who else can be made to pay)

Section 24 imports Taxes Act Sections 53–61, which extend liability and collection beyond the taxpayer:

• Section 53 — representative taxpayers; Section 54 — their liability; Section 55 — their right of indemnity; Section 56 — their personal liability;
• Section 58 — the Commissioner's power to appoint an agent to pay tax out of money held for or owing to the taxpayer (the garnishee / "agent appointment" power — e.g. a bank, debtor or tenant directed to pay the taxpayer's CGT);
• Section 59 — the Commissioner's remedies against an agent or trustee;
• Section 60 — the power to require information;
• Section 61 — public officers of companies (the named individual answerable for a company's tax compliance).

This is the engine of third-party recovery: where a taxpayer will not pay, ZIMRA can reach the money in the hands of those who hold it or owe it, and can hold a company's public officer accountable.

Section 25 — objections and appeals (the taxpayer's shield)

Enforcement is balanced by Section 25: a taxpayer aggrieved by an assessment under the Act, or by a listed Commissioner's decision (including decisions under Section 8(2)(b)/(e), Section 11, Section 13(3), Section 14 (fair market price), Section 15 (same-control transfers), Section 19(1) proviso, and the principal-private-residence definition and elections in Section 21), may object within 30 days of the notice of assessment or written notification of the decision, in the prescribed manner. Section 25(2) applies Taxes Act Section 62 (objections) and Sections 63–70 (objections and appeals), routing appeals through the established income-tax appeal machinery (to the Fiscal Appeal Court and onward). A proviso bars a further objection to a previous year's assessed capital loss. Sommer Ranching (Pvt) Ltd v COT 99-SC-065 is noted in the section as authority within this appeal framework.

Section 26 — day and place for payment, interest, and recovery powers

Section 26 (substituted by Act 16 of 2007 w.e.f. 1 January 2008) is the payment-and-recovery hinge:

• Section 26(1) — tax is due and payable: (a) no later than 30 days from the date a specified asset under Section 18(1) or 19(1) (suspensive/credit sales) accrues; (b) otherwise, no later than 30 days from the date title is formally transferred to the taxpayer; or (c) no later than the withholding dates under Sections 22C/22D/22E if earlier.
• Section 26(2) — tax is payable at any ZIMRA branch/office or through a notified agent.
• Section 26(3) — if tax is not paid by the due date, interest at the Minister's fixed rate runs on the unpaid balance until paid in full; the Commissioner may, in special circumstances, extend time without charging interest.
• Section 26(4) — for collecting tax and interest, the Commissioner has the same powers as the Taxes Act confers for collecting income tax, applied with necessary changes. This single subsection pulls the entire income-tax recovery toolkit (civil proceedings for the tax as a debt due to the State, agent appointments, etc.) into CGT.

Section 27 — offences, evidence, forms (the criminal layer)

Section 27 imports Taxes Act Sections 81–86 (offences), 87–88 (evidence and proof), 89 (forms, authentication and service of documents) and 90 (regulations). CGT non-compliance — failure to furnish returns, false statements, evasion — is therefore prosecutable under the income-tax offence provisions, and the income-tax evidentiary presumptions (e.g. the production of an assessment as proof) apply.

Section 29 — the general anti-avoidance rule

Section 29 applies Taxes Act Section 98 (the GAAR) to CGT, allowing the Commissioner to disregard or reconstruct artificial or fictitious transactions whose sole or main purpose is the avoidance of CGT — the ultimate backstop against structured non-payment.

Part IIIA enforcement — Section 22H penalty and Section 22G returns

For capital gains withholding tax (Part IIIA), Section 22H(1) makes a depositary (Section 22C) or agent (Section 22D) who fails to withhold or remit personally liable for (a) the tax that should have been withheld and (b) a further amount equal to 15% of that tax. Section 22H(2) lets the Commissioner waive the whole or part of the 15% where satisfied the failure was not due to any intent to evade. Section 22G requires depositaries to furnish returns. Section 22I allows refunds of over-withheld tax, but only on a claim made within 6 years, with interest payable if ZIMRA does not refund within 60 days (unless the taxpayer's own defective return caused the delay). Section 22J allows withheld tax as a credit against the final CGT, with any excess refunded.

Sections 30A / 32 — the registration chokepoint

Section 30A (and the wrongly-numbered duplicate Section 32) bar the Registrar of Deeds (under the Deeds Registries Act [Chapter 20:05]) and the share-transfer registrar (for companies under the Companies and Other Business Entities Act [Chapter 24:31]) from executing, attesting or registering any acquisition of a specified asset unless a ZIMRA certificate confirming the CGT has been paid is submitted. Section 30A(2) extends this to cessions of land-development-scheme stands and condominium membership interests. This is enforcement by gatekeeping: the value the buyer wants (registered title) is withheld until the tax is satisfied.

Section 31 — third-party reporting (detection)

Section 31 compels information flow to the Commissioner:

• Section 31(1) — the Registrar of Deeds must notify the Commissioner, at required intervals, of all transfers of immovable property registered, with the names and addresses of transferor and transferee and the price.
• Section 31(2) — whenever a marketable security is sold by or through a bank (Banking Act [Chapter 24:20]), a building society (Building Societies Act), or a licensed broker (Securities and Exchange/Securities Act), that institution must notify the Commissioner of the parties, the nature of the security, and the price.
• Section 31(3) — subsection (2) may be suspended by ministerial notice.

This converts deeds registries and financial intermediaries into a detection network, so ZIMRA can match third-party data against filed CGT returns.

Enforcement is best understood as a cascade that escalates from voluntary compliance to forced recovery and prosecution. We walk each stage.

Stage 1 — The obligation and the deadline

On a disposal of a specified asset, the taxpayer must file the CGT return (Form CGT 1) and pay the tax. Section 26 sets the deadline at 30 days from formal transfer of title (or from accrual in suspensive/credit sales). Where a withholding obligation applies (Part IIIA), tax is collected earlier, at the depositary/agent stage, and credited under Section 22J.

Stage 2 — Detection

If the taxpayer does not file or under-declares, ZIMRA detects the gap through Section 31 third-party reports (deeds-registry transfers, broker/bank security sales) and the Section 30A clearance process, which routes every registrable transfer through the Authority. The Commissioner's information powers (Taxes Act Sections 39, 40, 44, 60, imported by Sections 23 and 24) let ZIMRA demand documents and examine records on oath.

Stage 3 — Assessment and additional tax

ZIMRA raises an assessment. Where no satisfactory return exists, it issues an estimated (best-judgement) assessment under Taxes Act Section 45 (imported by Section 23). Where there has been default or omission, it loads additional tax under Section 46. Under-assessments are re-opened by additional assessments under Section 47. The taxpayer's remedy is to object within 30 days (Section 25) and appeal (Sections 63–70 ITA).

Stage 4 — Interest

From the due date, interest accrues on unpaid tax under Section 26(3) (and is calculated under Taxes Act Section 97B, imported by Section 23) at the rate the Minister fixes by statutory instrument. Interest is compensatory — it runs regardless of fault — although the Commissioner may waive it in special circumstances where he extends time.

Stage 5 — Recovery

If the assessed tax remains unpaid, Section 26(4) arms the Commissioner with the full income-tax recovery toolkit. The principal weapons are: suing for the tax as a debt due to the State; appointing an agent under Taxes Act Section 58 (imported by Section 24) to pay over money held for or owed to the taxpayer (a garnishee on a bank account, debtor or tenant); pursuing representative taxpayers (Sections 53–56) and a company's public officer (Section 61); and, for withholding defaults, holding the depositary/agent personally liable plus 15% under Section 22H.

Stage 6 — The chokepoint

Independently of all the above, Section 30A ensures that a buyer cannot obtain registered title to land or shares until a ZIMRA certificate confirms the CGT is paid. For most disposals this is the decisive lever: the transaction the parties want simply does not complete until the tax is satisfied.

Stage 7 — Prosecution

For serious non-compliance — false returns, evasion, failure to furnish returns — Section 27 imports the criminal offences in Taxes Act Sections 81–86, and the evidentiary provisions (Sections 87–88) ease ZIMRA's proof. Conviction can carry fines and imprisonment under the income-tax penal provisions.

Why design it this way?

By borrowing the Income Tax Act's enforcement code, the legislature avoids duplicating (and having to keep in sync) a parallel set of recovery, offence and evidence rules; CGT automatically benefits from every refinement of the income-tax machinery. The CGT-specific overlays — withholding (with its own 15% penalty) and the registration chokepoint — exist because asset transfers offer a natural collection point that wage or trading income lacks: the moment of registration is a bottleneck the State can stand astride. Third-party reporting closes the loop by giving ZIMRA the data to police the small minority of disposals that escape the chokepoint.

Individuals — Example 1: late payment interest and the chokepoint

Farai sells a residential plot in Harare; title transfers on 1 March 2025. His CGT (post-22 Feb 2019 asset, 20% of gain) is USD 12,000, due within 30 days — by 31 March 2025. He pays on 30 June 2025, three months late. Under Section 26(3), interest runs on the USD 12,000 from 1 April 2025 to 30 June 2025 at the Minister's fixed rate. If that rate is, say, 10% per annum:

Crucially, Farai could not register the buyer's title until ZIMRA issued the Section 30A certificate, which it does only once the USD 12,000 plus interest is paid — so the chokepoint, not a lawsuit, is what actually secures payment.

SMEs — Example 2: estimated assessment and additional tax for non-filing

Mhuka Traders (a private company) sells a warehouse but files no CGT return. ZIMRA learns of the transfer through the Section 31(1) deeds-registry report. It raises an estimated assessment under Taxes Act Section 45 (imported by Section 23), estimating the gain at USD 80,000 → CGT USD 16,000 (20%), and loads additional tax under Section 46 for the omission, plus interest under Section 26(3)/Section 97B. If additional tax were loaded at, say, 50%:

Mhuka Traders may object within 30 days (Section 25); if it can prove a lower gain (e.g. higher base cost and the Section 11(2) deductions), the estimate is reduced on objection. The burden of proving the assessment wrong lies on the taxpayer under the imported appeal provisions.

Withholding agents — Example 3: Section 22H personal liability plus 15%

A conveyancer (agent) handling a land sale should have withheld capital gains withholding tax of USD 9,000 from the seller's proceeds under Section 22D but failed to do so. Under Section 22H(1) the conveyancer becomes personally liable for:

If the conveyancer satisfies the Commissioner the failure was not due to any intent to evade, the Commissioner may waive the USD 1,350 under Section 22H(2) — but the USD 9,000 itself remains payable. The withheld amount, once paid, is credited to the seller under Section 22J.

Large corporates / multinationals — Example 4: agent appointment (garnishee)

A corporate seller with an assessed CGT debt of USD 200,000 refuses to pay. Using Taxes Act Section 58 (imported by Section 24) and the recovery power in Section 26(4), the Commissioner appoints the company's bank as agent, directing it to pay over USD 200,000 from the company's account. The bank, as appointed agent, must comply; the company's public officer (Section 61) remains answerable for the compliance failure. No court judgment is needed to operate the agent-appointment power — it is a self-help statutory recovery mechanism.

The following authorities, confirmed in the source materials, frame CGT enforcement:

Sabeta M v Commissioner-General: ZIMRA 12-HH-079 (High Court). Held that ZIMRA is not permitted to refuse to assess and issue a CGT certificate once the tax is paid. The case disciplines the enforcement chokepoint: the Section 30A certificate is a gate, not a weapon — once the tax is satisfied, the Authority must complete the assessment and issue the certificate so the transfer can register. It protects taxpayers against the chokepoint being used to extract more than is due or to stall a paid-up transfer.

Sibanda v Masanga 24-SC-090 (Supreme Court). ZIMRA refused to issue a CGT clearance because the fair market price had devalued so much over fifteen years that the owner could not pass transfer. It illustrates the real-world friction of the Section 30A clearance and the Section 14 fair-market-price power converging at the registration gate, and the practical leverage ZIMRA holds at that point.

Law Society of Zimbabwe & Mollat P.M. v Minister of Finance (with AG intervening) 99-SC-092 (Supreme Court). A constitutional challenge touching the Part IIIA withholding regime; the Act records that Section 36 of the Finance Act 29 of 1998, prior to a 1999 amendment, was ultra vires the Constitution and of no force between 1 January and 7 July 1999. The principle: the withholding-and-refund machinery must operate within constitutional limits, and defectively enacted collection provisions can be struck down — a reminder that enforcement powers are not unbounded.

Sommer Ranching (Pvt) Ltd v COT 99-SC-065 (Supreme Court). Noted within the objections-and-appeals framework (Section 25) and as authority on the Section 14 fair market price substitution. It anchors the principle that valuation disputes — the commonest CGT enforcement battleground — are resolved through the objection-and-appeal process, with the Commissioner's market-value determination challengeable on appeal.

• Confusing interest, additional tax, and penalty. Interest (Section 26(3)/Section 97B) is compensatory and runs automatically on late tax; additional tax (Section 46 ITA) is a punitive loading for default/omission; the 15% in Section 22H is a withholding-specific penalty on agents/depositaries. They are distinct, can stack, and have different waiver tests.
• Assuming the chokepoint can be bypassed. No Section 30A certificate, no registered title — for both land (Deeds Registry) and shares (share-transfer registrar). Parties who try to "complete" without clearance simply cannot perfect the transfer.
• Agents thinking the seller bears the withholding default. Under Section 22H, the depositary/agent who failed to withhold is personally liable for the tax and 15% — the obligation does not bounce back to the seller. Conveyancers and brokers must withhold.
• Missing the 30-day objection window. Under Section 25, objection must be lodged within 30 days of the assessment or decision notice. Late objection forfeits the challenge (subject to the Commissioner's discretion to condone under the imported provisions). Enforcement proceeds on an unobjected assessment.
• Underestimating third-party reporting. Section 31 feeds ZIMRA the deeds-registry and broker/bank data; non-disclosure is readily detected by data-matching. "They won't know" is a false premise.
• Ignoring representative-taxpayer and public-officer liability. A company's public officer (Section 61) and representative taxpayers (Sections 53–56) can be personally pursued — enforcement is not confined to the abstract company.
• Forgetting the criminal layer. Beyond civil recovery, Section 27 imports the offences (Sections 81–86 ITA): false returns and evasion are prosecutable.
• Over-claiming refunds late. Refund claims (including over-withheld tax under Section 22I) must be made within 6 years; stale claims are barred.

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 enforcement is borrowed, not built. The Capital Gains Tax Act [Chapter 23:01] imports the Income Tax Act [Chapter 23:06] enforcement code via Section 23 (assessments — incl. Section 45 estimates, Section 46 additional tax, Section 97B interest), Section 24 (representative taxpayers/agents — incl. Section 58 garnishee, Section 61 public officer), and Section 27 (offences Sections 81–86, evidence, forms), with Section 26(4) conferring the full income-tax recovery powers.
• Payment is due within 30 days of formal transfer of title (or accrual on suspensive/credit sales) under Section 26, with interest on late payment at the Minister's fixed rate (Section 26(3), calc. per Section 97B).
• Withholding has its own penalty. Section 22H makes a defaulting depositary/agent personally liable for the tax plus 15%, with the 15% waivable only where there was no intent to evade; withheld tax credits to the seller under Section 22J; refunds are time-barred at 6 years (Section 22I).
• The registration chokepoint is the decisive lever. Sections 30A/32 bar the Registrar of Deeds and share registrar from registering a transfer without a ZIMRA clearance certificate — but Sabeta 12-HH-079 holds ZIMRA must issue it once the tax is paid.
• Detection is built in. Section 31 compels the Registrar of Deeds, banks, building societies and brokers to report property and security transfers to the Commissioner.
• Rights bound the powers. Section 25 gives a 30-day objection right (appeals via ITA Sections 62–70); the GAAR (Section 29 / ITA Section 98) backstops against artificial avoidance; constitutional limits apply (Law Society & Mollat 99-SC-092).
• Distinguish the money labels: interest (compensatory, automatic), additional tax (punitive, for default/omission, Section 46 ITA), and the 15% withholding penalty (Section 22H) are separate and can stack.
• Policy insight: by collecting at the transfer point (withholding + chokepoint) and matching against third-party reports, the State turns an episodic, easily-concealed tax into a substantially self-enforcing one.

Table 1 — The CGT enforcement toolkit (imported and native)

Table 2 — Interest vs additional tax vs withholding penalty

Diagram — The CGT enforcement cascade

flowchart TD
 A[Disposal of specified asset] --> B{Return filed and tax paid within 30 days? Section 26}
 B -->|Yes| C[Section 30A certificate issued - title registers]
 B -->|No| D[Detection: Section 31 reports + Section 30A gate]
 D --> E[Estimated assessment - ITA Section 45 via Section 23]
 E --> F[Additional tax - ITA Section 46]
 F --> G[Interest accrues - Section 26(3)/Section 97B]
 G --> H{Taxpayer objects within 30 days? Section 25}
 H -->|Yes| I[Objection/appeal - ITA Sections 62-70]
 H -->|No| J[Recovery powers - Section 26(4)]
 J --> K[Agent appointment / garnishee - ITA Section 58 via Section 24]
 J --> L[Pursue representative taxpayer / public officer - Sections 53-56, 61]
 J --> M{Evasion or false return?}
 M -->|Yes| N[Prosecution - ITA Sections 81-86 via Section 27]
 I --> O[Assessment confirmed or reduced]
 C --> P[Withholding default? Section 22H agent liable tax + 15%]

Statutes & sections

• Capital Gains Tax Act [Chapter 23:01]
• Section 22G — depositaries to furnish returns; Section 22H — penalty for non-payment of withholding (tax + 15%; waiver of 15% if no intent to evade); Section 22I — refund of overpayments (6-year claim limit; interest); Section 22J — credit for tax withheld.
• Section 23 — applies Income Tax Act Sections 37–52, Part VIIIA, Section 97B (returns, estimated assessments Section 45, additional tax Section 46, additional assessments Section 47, interest Section 97B).
• Section 24 — applies Income Tax Act Sections 53–61 (representative taxpayers; agent appointment Section 58; remedies against agents/trustees Section 59; public officers Section 61).
• Section 25 — objections and appeals: 30-day objection; applies Income Tax Act Sections 62–70.
• Section 26 — day/place for payment (30 days); interest on late payment (Section 26(3)); recovery powers (Section 26(4)).
• Section 27 — applies Income Tax Act Sections 81–86 (offences), 87–88 (evidence/proof), 89 (forms/service), 90 (regulations).
• Section 29 — applies Income Tax Act Section 98 (GAAR).
• Section 30A / Section 32 — no registration of a specified-asset acquisition without a ZIMRA clearance certificate.
• Section 31 — reporting by Registrar of Deeds, banks, building societies and brokers.
• Income Tax Act [Chapter 23:06] — Sections 37–52, 53–61, 62–70, 81–90, 97B, 98 (imported as above).
• Finance Act [Chapter 23:04] — Section 38 (CGT rates), Section 39 (withholding rates), Section 39A (foreign-currency payment); CGT (Rate of Interest) Notices fixing the Section 26(3) interest rate (e.g. SI 281/2019, SI 54/2021, SI 211/2022).

Case law

• Sabeta M v Commissioner-General: ZIMRA 12-HH-079 — ZIMRA must assess and issue the CGT certificate once the tax is paid (limit on the Section 30A chokepoint).
• Sibanda v Masanga 24-SC-090 — clearance refused on devalued fair market price; force of the Section 30A gate and Section 14 valuation power.
• Law Society of Zimbabwe & Mollat P.M. v Minister of Finance (AG intervening) 99-SC-092 — constitutional limits on the Part IIIA withholding regime.
• Sommer Ranching (Pvt) Ltd v COT 99-SC-065 — objections/appeals and Section 14 fair market price.

ZIMRA guidance

• Comprehensive Guide to Form CGT 1 — ZIMRA External Guide — the CGT return and assessment process.
• Comprehensive Guide to the Special CGT Return — ZIMRA External Guide — special CGT return procedures.

Cross-references (TAXTAMI chapter)

• CGT — Payment and Recovery of CGT — the Section 26 due dates and recovery mechanics in depth.
• CGT — Withholding Tax on CGT — Part IIIA depositary/agent obligations and the Section 22H penalty.
• CGT — Objections and Appeals — the Section 25 / ITA Sections 62–70 challenge route.
• CGT — Returns and Assessments — Form CGT 1 and the imported assessment provisions.
• Income Tax — Tax Administration — the parent enforcement code (registration, assessments, objections, penalties, ZIMRA powers) that CGT imports.