Customs Valuation — The Six WTO Methods Applied to Zimbabwean Imports

Customs valuation is the discipline of establishing the monetary value for duty purposes (VDP) — also called the Value for Duty Purposes or customs value — of imported goods, which is the base on which the ad valorem duty rates derived from tariff classification are applied. Having mastered Tariff Classification in the previous module (the process that assigns each consignment its Harmonized System (HS) code and therefore its rate of duty under the Tariff Notice), we now turn to the second pillar of the classification → valuation → origin → duty spine: the determination of how much the goods are worth for the purpose of charging duty. Classification answers "at what rate?"; valuation answers "on what amount?". The two together, refined by origin and preference, produce the duty payable.

In Zimbabwe, customs valuation is governed by Part X (Sections 104 to 116) of the Customs and Excise Act [Chapter 23:02], read with the First Schedule principles and the Customs and Excise General Regulations (the General Regulations, the project copy being the 2021 consolidation). Part X is a near-verbatim domestication of the international standard: Article VII of the General Agreement on Tariffs and Trade (GATT) 1947 and the Agreement on Implementation of Article VII of the GATT 1979/1994 — the WTO Valuation Agreement (WTOVA), both of which Section 104(1) of the Act expressly defines as "the Agreements". Zimbabwe therefore applies the same six-method hierarchy that binds all WTO members.

The cardinal rule is in Section 105 and Section 106: the value for duty purposes is, first and foremost, the transaction value — the price actually paid or payable for the goods when sold for export to Zimbabwe, adjusted under Section 113. This primary method is mandatory wherever it can be applied; an officer may not jump to another method merely because it is convenient or yields more revenue. Only where transaction value cannot be established do the five fallback methods apply, and they apply in strict sequential order: (2) transaction value of identical goods (Section 107); (3) transaction value of similar goods (Section 108); (4) deductive value (Section 109); (5) computed value (Section 110); and (6) the fall-back / residual method (Section 111). The hierarchy is fixed, with one permitted flexibility: under the proviso to Section 109(1) the importer may request that the computed method (Section 110) be tried before the deductive method (Section 109).

Three adjustment mechanics dominate practice. First, under Section 113(1) certain costs incurred by the buyer but not already in the price — commissions and brokerage (other than buying commission), the cost of containers and packing, the apportioned value of assists (materials, tools, dies, design work supplied free or at reduced cost), royalties and licence fees that are a condition of sale, and proceeds of resale that accrue to the seller — must be added. Second, under Section 113(2) the cost of transport and insurance to the place of importation in Zimbabwe is added, converting an FOB (Free On Board) price into a CIF (Cost, Insurance, Freight) base; the Act supplies deeming percentages where actual figures are absent — notably 15% of FOB for combined air freight-and-insurance, 1% of FOB for insurance on non-air transport, and freight deemed at 5% of FOB for goods routed through neighbouring states (Botswana, South Africa, Lesotho, Eswatini, Mozambique, Zambia, Namibia, Malawi) or 7.5% of FOB for goods from elsewhere in Africa, in each case in addition to proved primary freight. Third, under Section 113(3) internal Zimbabwean transport costs and separately-identified buying commission are deducted.

Currency conversion follows Section 115A: foreign-currency values are converted at the customs exchange rate ruling at the time of entry — the selling rate designated by the Commissioner in consultation with the Reserve Bank of Zimbabwe and published (ZIMRA issues Rates of Exchange for Customs Purposes on a fortnightly basis). The declaration of value is lodged on Form 52A or Form 53A under regulation 24 of the General Regulations, with exemptions for duty-free goods, consignments not exceeding US$100 VDP, temporary imports, and non-merchandise goods.

Valuation does not stop at the customs value. The full duty/tax cascade runs: customs value → customs duty (tariff-line rate, less any preference or rebate) → surtax (where listed) → excise (where applicable) → VAT on importation. Critically for Zimbabwe, Section 12(2) of the VAT Act [Chapter 23:12] defines the import-VAT base as the value for customs duty purposes plus any duty, excluding surtax, levied under the Customs Act — so import VAT is charged on customs value plus customs duty plus excise but NOT plus surtax, at the standard rate of 15.5% with effect from 1 January 2026. This is the single most important Zimbabwe-specific computational subtlety and the most common source of import-VAT errors.

ZIMRA enforcement interest in valuation is intense because under-valuation is the most prevalent revenue leakage in the country, channelled through manipulated invoices, undeclared assists and royalties, fragmented or "split" invoicing, false related-party pricing, and freight under-statement. Section 111A specifically empowers the Commissioner to reject a doubtful declaration and revalue, and Section 114 confirms that acceptance of a bill of entry and release of goods is never a final determination of value — leaving the door open to post-clearance audit and reassessment within the record-keeping window. This lesson walks Part X clause by clause, defines every term of art, traces the ASYCUDA World procedure, and works the computations in full.

Every ad valorem customs charge in Zimbabwe — customs duty expressed as a percentage, surtax expressed as a percentage, and value-added tax on importation — is a percentage of a value. If that value is wrong, every charge built on it is wrong. Tariff classification, which we studied in the previous module, fixes the rate: it tells us that a cotton T-shirt falls in subheading 6109.10.00 and bears duty of 40% + US$3.00/Kg under the Tariff Notice (SI 203 of 2022). But a rate is meaningless without a base. 40% of what? Customs valuation answers that question. It is, quite literally, the multiplicand to classification's multiplier. For this reason valuation sits second in the classification → valuation → origin → duty spine: you cannot compute duty until you know both the rate (classification) and the base (valuation), as adjusted for origin and preference.

To a newcomer the idea seems trivial — surely the value is just the invoice price? In a perfect world of arm's-length sales between unrelated parties, with honest invoices and all costs disclosed, it very nearly is. But international trade is not that world. Prices are manipulated to reduce duty. Buyers and sellers are related and shift value between themselves. Goods are supplied with "free" tooling, moulds, or designs whose value never appears on the invoice. Royalties are paid separately to a third company. Freight is understated or disguised. Goods arrive as gifts, samples, or the personal effects of travellers, with no sale and therefore no price at all. The whole architecture of Part X exists to convert these messy commercial realities into a single, defensible, internationally-comparable figure — the value for duty purposes — using a method hierarchy that is transparent, predictable, and resistant to both taxpayer manipulation and arbitrary official inflation.

A.1 Defining the foundational terms

Before going further, define the load-bearing vocabulary, because the rest of the lesson depends on it.

• Value for duty purposes (VDP) — also Value for Duty Purposes or customs value — is the value, determined under Part X, to which the tariff-line duty rate is applied. It is the output of the valuation process. The Act uses "value for duty purposes" throughout (see Section 105).
• Transaction value is defined by Section 104(1) as "the value determined in terms of section one hundred and six" — i.e. the value produced by the primary method. Loosely, it is the adjusted price actually paid or payable for the goods sold for export to Zimbabwe.
• Price actually paid or payable is defined at length in Section 104(1): the sum of all payments made, or to be made, by or on behalf of the importer to the seller (or to a person related to the seller, or to a third party for the seller's benefit), plus the value of any consideration or services rendered by or on behalf of the importer to the seller. It captures total consideration, not just what the invoice happens to show.
• FOB (Free On Board) is the price of the goods at the point of export, before international insurance and freight. It is the building block of the customs value.
• CIF (Cost, Insurance, Freight) is FOB plus insurance plus freight to the place of importation — the figure to which valuation adjustments are applied to reach the customs value. Zimbabwe, like most developing economies, values on a CIF basis, meaning international transport and insurance to the Zimbabwean place of importation form part of the dutiable value (this is permitted by the WTO Valuation Agreement and effected through Section 113(2)).
• Customs Procedure Code (CPC) is the coded purpose of a declaration in ASYCUDA World (home consumption, warehousing, transit, temporary import, re-export, etc.) that drives duty treatment and obligations. Valuation interacts with the CPC because the procedure chosen affects when and on what base duty is assessed.
• Duty Paid Value (DPV), in the generic customs cascade, is customs value plus customs duty plus surtax plus excise — but note the crucial Zimbabwean qualification developed in section B and E below: the VAT-on-importation base under Section 12(2) of the VAT Act is customs value plus duty excluding surtax, so the generic DPV and the Zimbabwean import-VAT base are not identical.

A.2 Where valuation sits, and where enforcement bites

Valuation is engaged on every import entry for home consumption that bears ad valorem charges, and on many that bear specific charges too (because surtax and VAT are ad valorem even where the customs duty is specific). It is engaged at every border post — Beitbridge (the busiest, on the South African frontier), Forbes (Mutare/Machipanda), Chirundu and Kazungula (Zambia), Plumtree (Botswana), Nyamapanda (Mozambique) and Victoria Falls — at the airports for air cargo and passengers' commercial baggage, and at postal and courier hubs. It is also the single largest battlefield of post-clearance audit (PCA): because Section 114 says release is never a valuation, ZIMRA can and routinely does revisit declared values long after the goods have gone, using the six-year record-keeping obligation established in the registration module (Section 223) to reconstruct the true price actually paid or payable. A clearing agent who accepts a client's suspiciously low invoice at face value is not merely risking a reassessment; under Section 218 (agent and principal jointly liable) and the value-declaration provisions, the agent shares the exposure.

Customs valuation in Zimbabwe rests on a tightly interlocking set of domestic provisions and international instruments. This section identifies each by number and states what it provides, marching through Part X of the Act in order and then the subsidiary and international layers.

B.1 The charging anchor: Sections 86, 87 and 105

The duty to pay customs duty is imposed by Section 86 (customs duty charged on imported goods at the rates in the customs tariff), and the rate is fixed by classification under Section 87 (studied previously) read with the Tariff Notice issued under Section 225. Section 105 ("Value for duty purposes") is the bridge: it provides that, for the purpose of assessing duty and for any declaration or oath as to value, the value of imported goods "shall, subject to this Act, be the transaction value thereof as established or determined in terms of sections one hundred and six to one hundred and twelve". Section 105(2) adds a de minimis rule: if the value of goods required to be entered separately is one dollar or less, no account is taken of it.

B.2 Part X interpretation: Section 104

Section 104 is the definitional engine of the whole Part. It defines:

• "Agreements" — Article VII of GATT 1947 and the Agreement on Implementation of Article VII of GATT (Geneva, 12 April 1979), i.e. the WTO Valuation Agreement. This is the textual hook that makes Zimbabwe's law co-extensive with the international standard and makes WTO interpretive materials persuasive.
• "buying commission" — an amount paid by or on behalf of the importer to a person who, as the importer's agent, represented him abroad in purchasing and paying for the goods, subject to a detailed proviso (paragraphs (i)–(vi)) ensuring the "agent" is a true buying agent and not a disguised seller, producer, transporter, or commission-taker. Buying commission is significant because, uniquely among commissions, it is excluded from the customs value (added back nowhere and expressly deductible under Section 113(3)(b)).
• "identical goods" — goods manufactured in the same country, the same in all material respects (physical characteristics, quality, reputation) save minor appearance differences, excluding goods incorporating Zimbabwean engineering, development, design, plans or sketches. Used in the Section 107 method.
• "similar goods" — goods manufactured in the same country which, though not alike in all respects, have like characteristics and component materials enabling them to perform the same functions and be commercially interchangeable, again excluding goods reflecting Zimbabwean design inputs. Used in the Section 108 method. Section 104(2) directs that, in deciding similarity, regard is had to quality, reputation and trademark.
• "price actually paid or payable", "computed value", "general expenses", "goods of the same class or kind", "royalty", and "unit price" — each defined to support the methods that use them.
• The related-persons test in Section 104(3): persons are "related" only if they are officers/directors of one another's businesses; partners; employer and employee; bodies corporate where a person owns/controls 5% or more of the voting stock of both; one controls the other; both are controlled by a third; together they control a third; or they are members of the same family. Section 104(4) treats a sole agent/distributor/concessionaire as related only if they fall within Section 104(3). The test matters because relationship can disqualify the transaction value under Section 106(1)(d) unless saved by Section 106(2).

B.3 The six methods, in order: Sections 106 to 111

• Section 106 — Transaction value (primary method). The VDP is the transaction value — the price actually paid or payable for the goods sold for export to Zimbabwe, adjusted under Section 113 — provided four conditions are met: (a) no restrictions on the buyer's disposal or use of the goods (other than legal restrictions, geographic resale limits, or restrictions not substantially affecting value); (b) the sale or price is not subject to a condition or consideration whose value cannot be determined; (c) no part of the proceeds of resale accrues to the seller unless an adjustment can be made under Section 113; and (d) subject to subsection (2), the buyer and seller are not related. Section 106(2) rescues a related-party transaction where either the relationship did not influence the price, or the importer proves the value closely approximates a "test value" (transaction value of identical/similar goods to unrelated Zimbabwean buyers, or a deductive value of such goods, at or about the same time).
• Section 107 — Transaction value of identical goods (first alternative). Where Section 106 fails, the VDP is the transaction value of identical goods sold for export to Zimbabwe at the same commercial level and substantially the same quantity, exported at or about the same time. Section 107(2) allows adjustment for differences in commercial level/quantity; Section 107(3) for differences in transport cost/distance; Section 107(4) directs that where more than one value is found, the lowest is taken; and Section 107(5) lets the importer produce, or enable tracing of, a bill of entry on which the Department accepted an identical-goods value entered within three months.
• Section 108 — Transaction value of similar goods (second alternative). Identical mechanics to Section 107 but using similar goods; subsections (2)–(5) of Section 107 apply mutatis mutandis.
• Section 109 — Deductive value (third alternative). Where 106–108 fail, value is built backwards from the unit price at which the imported goods (or identical/similar imported goods) are sold in Zimbabwe in the greatest aggregate quantity to unrelated persons at or about the time of importation (subsection (2)), or, failing that, at the earliest date after importation but not later than 90 days (subsection (3)), or, if sold only after further processing, on that basis (subsection (4)). Prescribed deductions (subsection (5)) strip out Zimbabwean profit and general expenses, internal transport and insurance, Zimbabwean duties and taxes, and any value added by processing — leaving the import value. The proviso to Section 109(1) preserves the importer's right to ask that computed value (Section 110) be tried before deductive value.
• Section 110 — Computed value (fourth alternative). Value is built forwards from the producer's costs: the value of materials, the producer's costs and expenses of production, packing, the apportioned value of assists, transport/insurance to the port of export, and the producer's usual profit and general expenses on goods of the same class or kind. It depends on cooperation from a foreign producer and is therefore rarely used in practice.
• Section 111 — Fall-back / residual method (final alternative). Where none of 106–110 works, the Commissioner determines value on the basis of a previous determination, or by applying Sections 106–109 with reasonable modification, or by any other reasonable means consistent with the Agreements, using information available in Zimbabwe. Section 111(3) lists seven prohibited bases the Commissioner may NOT use: the selling price of Zimbabwean-made goods; a system accepting the higher of two values; the domestic price in the country of export; the cost of production of the goods or identical/similar goods (except as permitted under computed value); the export price to a third country; a system of minimum customs values; and arbitrary or fictitious values. These prohibitions are the taxpayer's central protection against revenue-driven over-valuation.

B.4 The integrity gate and private imports: Sections 111A and 112

• Section 111A — Doubt as to truth or accuracy. Where the Commissioner or proper officer has reason to doubt the truth or accuracy of the importer's statement made for transaction-value purposes, he must (a) require further information to prove accuracy, and (b) if still in doubt after considering it, reject the statement and value the goods by whichever of Sections 107–111 is appropriate. This is the statutory basis for ZIMRA's reference-value and uplift practices and must be exercised with the procedural fairness the section spells out — request information first, decide afterwards.
• Section 112 — Valuation of goods imported privately. "Non-merchandise goods" means goods imported by an individual for personal use, not for trade. Where the declared value does not reflect a bona fide open-market price between unrelated parties, or has not been established or is incorrectly declared, the Commissioner may determine value from a previous determination or by adapting Sections 106–110. This is the provision behind the valuation of travellers' goods and personal effects (it interacts with the Travellers' Rebate, to be studied later).

B.5 The adjustments and conversion provisions: Sections 113, 114, 115 and 115A

• Section 113 — Adjustments. The arithmetic heart of valuation. Section 113(1) lists additions to the price actually paid or payable (commissions/brokerage except buying commission; cost of containers and packing; the apportioned value of assists — materials, tools, dies, moulds, design/engineering work done outside Zimbabwe; royalties and licence fees that are a condition of sale; and proceeds of resale accruing to the seller). Section 113(2) adds transport and insurance to the place of importation in Zimbabwe, with the deeming provisos: (i) air freight-and-insurance deemed 15% of FOB; (ii) the same 15% for air goods carried free/at reduced cost or as passengers' commercial baggage; (iii) insurance on non-air transport deemed 1% of FOB; (iv) freight deemed 5% of FOB (goods from Botswana, South Africa, Lesotho, Eswatini, Mozambique, Zambia, Namibia, Malawi) or 7.5% of FOB (other African countries) in addition to proved primary freight where no documentary delivery cost exists; and (d) postal charges, deemed 15% of FOB where not ascertainable. Section 113(3) lists deductions: internal Zimbabwean transport/handling/insurance, and separately-identified buying commission.
• Section 114 — Bill of entry / release not a valuation. Neither acceptance of a bill of entry stating a value nor release of the goods constitutes a determination of value. This preserves ZIMRA's right to revalue on post-clearance audit and is the legal underpinning of the entire PCA regime as it touches value.
• Section 115 — Payment of duty in foreign currency. The Minister may designate "foreign currency dutiable items" on which duty and import/VAT must be paid in United States dollars (with cross-rate conversion for other foreign currencies), and Section 115(3) allows designation of all tariff items. This reflects Zimbabwe's multi-currency reality.
• Section 115A — Rates of exchange. Foreign-currency values or cost elements are converted to Zimbabwean currency at the customs exchange rate at the time the goods were entered — the selling rate designated by the Commissioner in consultation with the Reserve Bank of Zimbabwe. ZIMRA publishes these Rates of Exchange for Customs Purposes fortnightly; the rate ruling at the date of entry governs, which is why timing of entry can change the duty payable.

B.6 Excise and surtax value for local manufacture: Section 116

For completeness, Section 116 governs the dutiable value for excise duty and surtax on goods manufactured in Zimbabwe (not imports): the value is determined by the Commissioner, generally as factory cost plus 25% (or a prescribed percentage), or the selling price if greater. This is the domestic-manufacture analogue of import valuation and is flagged here because excise computations in later modules will use it; the import side uses Part X proper.

B.7 Subsidiary regulation: the General Regulations

The General Regulations operationalise Part X: - Regulation 24 — Declaration of value. Every importer must lodge with each entry a declaration of value on Form 52A or Form 53A, "depending on the method of valuation used", subject to exemptions for: goods admissible free of duty under the customs and surtax tariffs or by agreement/suspension; dutiable goods of total VDP not exceeding US$100 per consignment; goods imported temporarily under Section 124; and non-merchandise goods under Section 112 — unless the proper officer specifically requests a declaration. Regulation 24(2) allows an importer seeking a Commissioner's ruling on value to submit Forms 54A and 54B. - Regulation 25 — Certificates of origin for lower rates. Lower (preferential) rates are not granted unless the importer produces the prescribed certificate of origin (e.g. Form 61 or 65 for the Zimbabwe/Botswana/Malawi customs agreement; the COMESA treaty form; and so on). This is where valuation hands off to origin and preference (the next module): valuation fixes the base; origin fixes which rate applies to that base. - The General Regulations also address returned and repaired goods (duty on the cost of repair, the value being established via the alternative methods in Sections 107–112 where there is no charge), keeping re-imports inside the Part X framework.

B.8 The international layer

Part X is the domestic face of: - GATT Article VII and the WTO Valuation Agreement (WTOVA) — the source of the six-method hierarchy, the primacy of transaction value, the "positive" (transaction-based) standard, and the prohibitions on arbitrary, fictitious and minimum values. The WTOVA's Interpretative Notes, the decisions and advisory opinions of the WCO Technical Committee on Customs Valuation (TCCV), and the WTO Committee on Customs Valuation are persuasive aids to interpreting the materially identical Zimbabwean text. - The Revised Kyoto Convention (RKC) and WTO Trade Facilitation Agreement (TFA) — which encourage advance valuation rulings, transparency and minimal intervention, and which underpin ZIMRA's ruling and AEO practices. - The regional preference instruments — SADC Trade Protocol (Annex I, Rules of Origin), COMESA (SI 244 of 2000) and AfCFTA — which do not change the valuation base but change the rate applied to it, and which therefore interlock with valuation through regulation 25.

B.9 Old law versus current law

Two points of change are worth flagging. First, the bulk of Part X was extensively amended by Act 17 of 1999, which brought the Zimbabwean text into line with the WTO Valuation Agreement (replacing the older "Brussels Definition of Value" notion of a notional open-market price with the positive transaction-value standard). Many subsections in Sections 104–111 carry the note "[amended by Act 17 of 1999]". Secondly, on the VAT side, duty was brought into the import-VAT base by the Finance (No. 3) Act 10 of 2009 with effect from 1 January 2010 (before that, import VAT was charged on the customs value alone). The current standard VAT rate used throughout this lesson is 15.5% with effect from 1 January 2026. Tariff lines, surtax coverage and exchange rates are edition- and period-specific; always confirm against the current Tariff Notice and the Rates of Exchange for Customs Purposes for the relevant fortnight.

Customs valuation is best understood as a sequential decision procedure: start at the top, and descend only when the method above genuinely cannot be applied. The WTO Valuation Agreement, and therefore Part X, is built on a single philosophical commitment — that the customs value should reflect, as closely as possible, the real commercial price of the specific goods being valued, determined from positive evidence rather than from notional or arbitrary constructs. Every rule below serves that commitment.

C.1 The hierarchy and the rule of sequence

The methods must be applied in order: Section 106, then 107, then 108, then 109, then 110, then 111. An officer may not skip a method that is available, and may not reach for a lower method merely because it produces more revenue. The only sanctioned flexibility is the importer's option, under the proviso to Section 109(1), to have computed value (Section 110) attempted before deductive value (Section 109) — a reversal of methods four and five at the importer's request, recognising that some traders find it easier to prove a producer's costs than to reconstruct Zimbabwean resale prices. Each descent must be justified: the file should record why the method above could not be used.

C.2 Method 1 — Transaction value (Section 106)

This is the method used for the overwhelming majority of entries. The customs value is the price actually paid or payable for the goods sold for export to Zimbabwe, adjusted under Section 113. Three elements deserve unpacking.

"Sold for export to Zimbabwe." There must be a sale, and it must be a sale that caused the goods to be exported to Zimbabwe. Gifts, consignment stock, goods on lease, goods imported by a branch from its own head office without a sale, and samples supplied free of charge are not sold and cannot be valued under Section 106 — they descend to the alternative methods (and, for personal imports, to Section 112). Where there is a chain of sales (manufacturer → middleman → Zimbabwean importer), the relevant price is the one for the sale that actually caused export to Zimbabwe.

"Price actually paid or payable." Per the Section 104(1) definition, this is total consideration — every payment to the seller, to persons related to the seller, and to third parties for the seller's benefit, plus the value of services/consideration rendered by the buyer to the seller. It is not limited to the face of the commercial invoice. A side payment, a separate "tooling charge", or an offset against a debt all form part of the price actually paid or payable.

The four conditions (Section 106(1)(a)–(d)). Transaction value is acceptable only if: (a) there are no disposal/use restrictions on the buyer beyond legally-imposed restrictions, geographic resale limits, or restrictions not substantially affecting value; (b) the sale/price is not subject to a condition or consideration whose value cannot be determined (e.g. "the price is X provided you also buy Y at an unstated discount"); (c) no part of the proceeds of resale accrues to the seller unless an adjustment can be made under Section 113; and (d) the buyer and seller are not related, unless saved by Section 106(2).

Related parties (Sections 104(3), 106(2)). Relationship alone does not defeat transaction value. Under Section 106(2), the value stands if either (i) the Commissioner is satisfied the relationship did not influence the price, or (ii) the importer demonstrates that the declared value closely approximates a "test value" — the transaction value of identical/similar goods sold to unrelated Zimbabwean buyers, or a deductive value of such goods, at or about the same time. The burden of triggering the examination lies with the officer (who must have grounds to suspect influence), but the burden of proving the price was uninfluenced, or of producing a test value, lies with the importer.

C.3 The adjustment engine — Section 113 (additions and deductions)

Whatever method ultimately applies, the Section 113 adjustments shape the figure. Master these and most valuation problems become arithmetic.

Additions under Section 113(1) (to reach the adjusted price under method 1): - Commissions and brokerage, except buying commission. A selling commission paid to the seller's agent is part of value; a genuine buying commission paid to the importer's own purchasing agent is not (and is deductible under 113(3)(b)). - The cost of containers treated as one with the goods for customs purposes, and the cost of packing (labour and materials). - Assists (Section 113(1)(b)): the apportioned value of materials, components and parts incorporated in the goods; tools, dies and moulds used to produce them; materials consumed in production; and engineering, development, art, design work, plans and sketches undertaken outside Zimbabwe and necessary for production — but only if supplied by the importer free of charge or at reduced cost and not already in the price. (Design work done in Zimbabwe is excluded, mirroring the identical/similar-goods definitions.) Assists are the classic hidden value: a Zimbabwean importer who ships free moulds to a Chinese factory must add the apportioned mould cost to the price. - Royalties and licence fees the buyer must pay, directly or indirectly, as a condition of sale of the goods for export to Zimbabwe — including patents, trademarks and copyright and the right to distribute or resell — but not charges for the right to reproduce the goods in Zimbabwe. - Proceeds of any subsequent resale, disposal or use that accrue to the seller.

Additions under Section 113(2) (to reach the CIF base, for every method): - Cost of transport and insurance from the place of manufacture to the place of export, plus charges incidental to placing the goods on board (Section 113(2)(a)). - Freight, insurance and other charges through an intermediate country where goods are routed via a third country (Section 113(2)(b)). - Freight and insurance from the place of loading to the place of importation in Zimbabwe (Section 113(2)(c)). - The deeming provisos to Section 113(2), used where actual figures are unavailable or unproved: - (i) & (ii) Air transport: freight and insurance together deemed 15% of FOB (including where goods are carried free, at reduced cost, or as passengers' commercial baggage). - (iii) Non-air transport: insurance deemed 1% of FOB unless the importer proves otherwise. - (iv) Non-air transport, no documentary delivery cost: freight deemed 5% of FOB in addition to proved primary freight where goods were transported from Botswana, South Africa, Lesotho, Eswatini (Swaziland), Mozambique, Zambia, Namibia or Malawi; or 7.5% of FOB in addition to proved primary freight for goods from any other African country. - (d) Postal imports: postage and insurance shown on the accompanying documents; where not ascertainable, deemed 15% of FOB.

Deductions under Section 113(3) (to strip out non-dutiable elements): - Internal transport within Zimbabwe — transportation, loading, unloading, handling, insurance and associated costs from the place of importation onward — to the extent included in the price. - Buying commission, if separately identified.

The logic is symmetrical: Section 113(2) pulls international transport into the dutiable value (the CIF principle); Section 113(3) keeps purely domestic Zimbabwean costs out of it.

C.4 Method 2 — Identical goods (Section 107); Method 3 — Similar goods (Section 108)

When there is no usable transaction value (no sale, an unacceptable price, an irremediable condition, or an uninfluenced related-party price that cannot be demonstrated), the officer looks outward to comparable importations. Section 107 uses identical goods — same country of manufacture, the same in all material respects bar minor appearance; Section 108 uses similar goods — same country, commercially interchangeable with like characteristics and component materials. The comparable must be sold for export to Zimbabwe at the same commercial level and substantially the same quantity and exported at or about the same time. Where the only comparable is at a different commercial level or quantity, Section 107(2) permits adjustment for those differences; Section 107(3) permits adjustment for transport/distance differences. Two safeguards protect the importer: Section 107(4) requires that, if several comparable values exist, the lowest be used; and Section 107(5) lets the importer produce, or point ZIMRA to, a bill of entry on which the Department accepted an identical-goods value within three months. Section 108 imports Section 107's machinery wholesale via Section 108(2).

C.5 Method 4 — Deductive value (Section 109)

Where comparables fail, valuation turns inward and backward: from the price at which the goods (or identical/similar imported goods) are sold in Zimbabwe. The base is the unit price at which the goods are sold in the greatest aggregate quantity to unrelated persons — at or about the time of importation (subsection (2)), failing which at the earliest date after importation but within 90 days (subsection (3)), failing which after further processing (subsection (4)). From that Zimbabwean selling price, Section 109(5) requires deductions for: commissions/profit and general expenses usual in Zimbabwean sales of the same class of goods; internal transport, handling and insurance from the place of importation; Zimbabwean duties and taxes on importation or sale; and (for processed goods) the value added by processing. Strip these out, and what remains approximates the import value. The "greatest aggregate quantity" rule prevents cherry-picking a single high-priced retail sale.

C.6 Method 5 — Computed value (Section 110)

The mirror image of deductive value: build the value forward from the producer's costs. Section 110(2) sums the value of materials; the producer's production costs and expenses; packing; the apportioned value of assists; transport and insurance to the port of export; and the producer's usual profit and general expenses on goods of the same class or kind sold to unrelated buyers. Because it requires a foreign producer to open its books, computed value is seldom used except for related-party imports where the producer cooperates.

C.7 Method 6 — Fall-back / residual (Section 111)

The method of last resort. The Commissioner determines value flexibly — on a previous determination, by adapting Sections 106–109 with reasonable modification, or by any other reasonable means consistent with the Agreements, using information available in Zimbabwe. The discipline lies in the seven prohibitions of Section 111(3): no Zimbabwean selling price of locally-made goods; no "higher of two values" system; no domestic price in the country of export; no cost-of-production basis (outside computed value); no third-country export price; no minimum-value system; and no arbitrary or fictitious values. These prohibitions are what separate a lawful fall-back determination from an unlawful revenue grab.

C.8 The integrity gate — Section 111A

Running parallel to the hierarchy is Section 111A, the doubt provision. If an officer reasonably doubts the truth or accuracy of a declared transaction value, the section prescribes a two-step due-process sequence: first require further information; then, only if doubt persists after considering it, reject the declaration and revalue under Sections 107–111. ZIMRA's "reference values" and value uplifts are lawful only when channelled through this provision and supported by genuine grounds for doubt — not as a blanket override of the transaction-value primacy that Section 106 commands.

Valuation is not an abstract calculation; it is a documented declaration processed through ASYCUDA World (the Automated System for Customs Data, ZIMRA's electronic clearance platform) and tested by risk targeting. The end-to-end procedure for a standard import for home consumption is as follows.

1. Assemble the valuation evidence. The clearing agent gathers the commercial invoice (showing the price actually paid or payable, the Incoterm, and the currency), the packing list, the Bill of Lading or Air Waybill (AWB) and freight invoice, the insurance certificate or premium note, any certificate of origin (Form 61/65, COMESA, SADC, or AfCFTA, where preference is claimed under regulation 25), and evidence of any assists, royalties or commissions.

2. Determine the method and the FOB. Confirm there is a sale for export to Zimbabwe and that the four Section 106 conditions are met — if so, method 1 applies. Identify the FOB value, stripping any post-export costs already in the invoice price and noting any costs to be added.

3. Convert the currency. Convert the foreign-currency FOB and cost elements to the declaration currency at the customs exchange rate ruling at the date of entry under Section 115A (ZIMRA's Rates of Exchange for Customs Purposes for the relevant fortnight). Where the goods are foreign currency dutiable items under Section 115, duty and import VAT are paid in United States dollars.

4. Build the CIF / customs value. Apply the Section 113 adjustments: add Section 113(1) items (commissions other than buying commission, containers, packing, assists, royalties, resale proceeds); add Section 113(2) transport and insurance (using the deeming provisos — 15% air, 1% non-air insurance, 5%/7.5% deemed freight, 15% post — where actuals are unavailable); deduct Section 113(3) internal transport and separately-identified buying commission. The result is the value for duty purposes (customs value).

5. Lodge the declaration of value. Complete Form 52A or Form 53A under regulation 24 (unless exempt: duty-free goods, VDP not exceeding US$100 per consignment, temporary imports under Section 124, or non-merchandise goods). Where a ruling on value is sought, lodge Forms 54A and 54B under regulation 24(2).

6. Capture the entry in ASYCUDA World. Lodge the Bill of Entry (the single universal Form 21 / SAD) with the correct CPC, declaring the HS classification (from the previous module), the value for duty purposes, the FOB/CIF breakdown, the country of origin, and any preference claim. Attach the supporting documents via the Document Processing (DTI) facility.

7. Risk targeting — Green / Yellow / Red lanes. ASYCUDA's risk engine routes the declaration. Green = released without intervention; Yellow = documentary check (the valuation documents are scrutinised — invoice authenticity, freight/insurance, assists, related-party indicators); Red = physical examination plus documentary check. Valuation discrepancies (a price well below ZIMRA reference values, missing freight, related-party flags) commonly trigger Yellow or Red and may invoke Section 111A.

8. Assessment. The system computes customs duty (customs value × tariff-line rate, less preference/rebate), surtax (where listed), excise (where applicable), and VAT on importation on the Section 12(2) base — customs value plus duty, excluding surtax — at 15.5%.

9. Payment and release. Duty, surtax, excise, import VAT and any levies are paid (in USD for forex dutiable items under Section 115), and the goods are released. Per Section 114, release is not a determination of value.

10. Post-clearance obligations. The importer retains all valuation records for six years (Section 223). ZIMRA may conduct post-clearance audit to test the declared value, reconstruct the price actually paid or payable, and reassess under Sections 111A/107–111 — with penalties for under-valuation.

Each example shows every line. Rates are confirmed against SI 203 of 2022 (Tariff Notice) where stated; surtax rates are flagged because the Surtax Tariff is not among the sources; the import-VAT rate is 15.5% from 1 January 2026; the import-VAT base excludes surtax per Section 12(2) of the VAT Act [Chapter 23:12].

E.1 Example 1 — Commercial T-shirts imported by sea/road (transaction value, compound duty)

Facts. A Harare retailer imports 5,000 cotton T-shirts, classified in the previous module to subheading 6109.10.00 (duty 40% + US$3.00/Kg, confirmed in SI 203 of 2022). The supplier in China sells the goods FOB Shanghai = US$20,000. Ocean freight Shanghai → Durban and road freight Durban → Beitbridge is proved at US$2,500. No insurance figure is shown. Total net weight = 1,000 Kg. The buyer and seller are unrelated; there are no assists, royalties, commissions or restrictions. Goods entered for home consumption; declaration in USD (a foreign currency dutiable item, Section 115).

Step 1 FOB (Shanghai) = US$ 20,000.00
Step 2 + Freight (proved, to Beitbridge place of importation) = US$ 2,500.00
 + Insurance: not shown -> Section 113(2) proviso (iii) deems 1% FOB = US$ 200.00 (1% x 20,000)
 = CIF / Customs Value (VDP) under Section 106 + Section 113 = US$ 22,700.00
Step 3 No First Schedule additions (no assists/royalties/commissions) -> VDP = US$ 22,700.00
Step 4 Customs duty (6109.10.00 = 40% ad valorem + US$3.00/Kg specific)
 Ad valorem component = 40% x 22,700.00 = US$ 9,080.00
 Specific component = US$3.00 x 1,000 Kg = US$ 3,000.00
 Customs duty (compound, both components) = US$ 12,080.00
Step 5 Surtax (if listed for 6109.10.00) = US$ 0.00
Step 6 Excise duty (not applicable to T-shirts) = US$ 0.00
Step 7 Import-VAT base (Section 12(2): Customs Value + duty, EXCLUDING surtax)
 = 22,700.00 + 12,080.00 = US$ 34,780.00
Step 8 VAT on importation = 15.5% x 34,780.00 = US$ 5,390.90
Step 9 Other levies = US$ 0.00
 TOTAL PAYABLE TO ZIMRA = duty + surtax + excise + import VAT
 = 12,080.00 + 0 + 0 + 5,390.90 = US$ 17,470.90

Note how the specific component (US$3/Kg) is unaffected by value — it is a deliberate anti-under-valuation device for textiles, ensuring a floor of duty even if the declared value is suppressed. Note also that surtax (if any) is excluded from the import-VAT base while customs duty is included.

E.2 Example 1A — Same goods imported by air (15% deeming)

Suppose instead the 5,000 T-shirts are air-freighted and no freight/insurance figures are produced. Under Section 113(2) proviso (i), air freight and insurance together are deemed 15% of FOB.

Step 1 FOB = US$ 20,000.00
Step 2 + Freight & insurance deemed (15% x 20,000) air = US$ 3,000.00
 = CIF / Customs Value (VDP) = US$ 23,000.00
Step 4 Customs duty: 40% x 23,000 = 9,200.00; + US$3 x 1,000 Kg = 3,000.00 = US$ 12,200.00
Step 7 Import-VAT base = 23,000.00 + 12,200.00 = US$ 35,200.00
Step 8 VAT on importation = 15.5% x 35,200.00 = US$ 5,456.00
 TOTAL PAYABLE = 12,200.00 + 5,456.00 = US$ 17,656.00

The single change of transport mode lifts the dutiable value (the 15% air deeming exceeds the proved sea/road cost), illustrating why mode of transport is a valuation variable, not a mere logistics detail.

E.3 Example 2 — Preferential versus non-preferential (the value base is the same; only the rate changes)

Facts. A Bulawayo distributor imports goods with a confirmed MFN customs duty of 40% and a customs value (VDP) of US$50,000. Compare (a) a non-preferential import (no valid certificate of origin) with (b) a SADC-originating import accompanied by a valid SADC certificate of origin satisfying the Rules of Origin (Annex I), where the line is fully phased down to 0% under the SADC Trade Protocol.

 (a) Non-preferential (b) SADC preferential
Customs Value (VDP) [same base] US$ 50,000.00 US$ 50,000.00
Customs duty rate 40% (MFN) 0%
Customs duty US$ 20,000.00 US$ 0.00
Surtax US$ 0.00 US$ 0.00
Import-VAT base (VDP + duty, excl surtax) US$ 70,000.00 US$ 50,000.00
VAT on importation @ 15.5% US$ 10,850.00 US$ 7,750.00
TOTAL PAYABLE TO ZIMRA US$ 30,850.00 US$ 7,750.00
SAVING from valid preference US$ 23,100.00

The lesson: valuation fixes the base identically in both cases — US$50,000 — but origin/preference changes the duty rate, and because the import-VAT base includes duty, the preference saving cascades into a lower VAT charge too. This is precisely why regulation 25 demands a valid certificate of origin before a lower rate is granted, and why valuation and origin are studied back-to-back.

E.4 Example 3 — Assists: free moulds supplied to the foreign producer (Section 113(1)(b))

Facts. A Zimbabwean manufacturer imports plastic components, FOB = US$30,000, sea freight proved US$1,500, no insurance shown. The importer had earlier shipped moulds to the Chinese producer free of charge; the moulds cost US$12,000 and are expected to produce four equal consignments, so US$3,000 is apportioned to this consignment.

Step 1 FOB = US$ 30,000.00
 + Assist: apportioned mould value (Section 113(1)(b)(ii)) = US$ 3,000.00
 Adjusted price = US$ 33,000.00
Step 2 + Freight (proved) = US$ 1,500.00
 + Insurance deemed 1% of FOB (Section 113(2)(iii)) = US$ 300.00
 = Customs Value (VDP) = US$ 34,800.00

Had the importer (wrongly) declared only the US$30,000 invoice and the freight, the value would have been understated by the US$3,000 assist plus the deemed insurance — a textbook under-valuation that PCA routinely uncovers by tracing the importer's outbound shipment of the moulds.

E.5 Example 4 — Deductive value backward computation (Section 109)

Facts. Goods are imported on consignment (no sale for export, so Section 106 fails; no identical/similar comparables, so Sections 107–108 fail). Identical imported goods are sold in Zimbabwe in the greatest aggregate quantity at US$100 per unit; 2,000 units were imported. Usual Zimbabwean profit and general expenses on this class of goods are 25% of the selling price; internal transport and insurance from Beitbridge are US$4 per unit; customs duty and import VAT attributable per unit total US$22.

Zimbabwe selling price (greatest aggregate quantity) = US$ 100.00 / unit
Less Section 109(5)(a) profit & general expenses (25%) = US$ 25.00
Less Section 109(5)(b) internal transport & insurance = US$ 4.00
Less Section 109(5)(c) Zimbabwe duty & import VAT = US$ 22.00
= Deductive unit value = US$ 49.00 / unit
Customs Value (VDP) = 49.00 x 2,000 units = US$ 98,000.00

The "greatest aggregate quantity" and the stripping of Zimbabwean profit, internal costs and taxes are what make the deductive figure a fair import value rather than an inflated retail price.

Valuation plays out differently across taxpayer groups, and ZIMRA calibrates its documentary demands and risk posture accordingly.

Individual travellers and returning residents. A traveller arriving at Beitbridge or Robert Gabriel Mugabe International Airport with goods for personal use imports non-merchandise goods valued under Section 112. There is usually no sale and often no invoice; the officer determines value from a previous determination or by adapting Sections 106–110, typically against ZIMRA's reference price lists for common items (phones, laptops, clothing). Under regulation 24 the traveller is exempt from lodging a Form 52A/53A value declaration for non-merchandise goods unless specifically asked. Valuation here interlocks with the Travellers' Rebate (Second Schedule), studied in a later module — the rebate reduces the duty, but value must still be established first.

Small cross-border traders. The informal and semi-formal traders who dominate Beitbridge and Plumtree typically import dutiable consignments of modest value. Where the VDP does not exceed US$100 per consignment, regulation 24 exempts the value declaration; many qualify for simplified clearance. Their principal valuation risk is fragmentation — splitting one economic consignment into several to stay under thresholds or to suppress value — which ZIMRA treats as a valuation-integrity offence.

SMEs (cross-border manufacturing and retail). A Bulawayo SME importing inputs or stock files full Form 21 entries with Form 52A/53A value declarations, commercial invoices, freight and insurance documents, and (where preference is claimed) certificates of origin. Their recurring valuation issues are assists (free tooling or designs sent abroad), royalties on branded goods, and related-party pricing where the SME imports from an affiliated regional supplier. The cascade impact is material because import VAT (15.5%) compounds on customs value plus duty.

Large corporates (mining houses, manufacturers, supermarket chains, multinationals). Large importers via Beitbridge and Plumtree present the most complex valuation profiles: related-party transactions (intra-group transfer pricing tested under Sections 104(3)/106(2)), substantial assists and royalties, chain sales, and high-volume clearance often supported by advance valuation rulings (Forms 54A/54B, regulation 24(2)) and AEO facilitation. For these traders ZIMRA's primary tool is post-clearance audit rather than border intervention — value is accepted provisionally at the frontier (Section 114) and tested in depth later.

Reported Zimbabwean customs-valuation decisions are comparatively sparse in the source materials; the field is governed predominantly by the statute (Part X) and, through the Section 104(1) definition of "the Agreements", by the WTO Valuation Agreement and its interpretive apparatus. Where disputes arise, the route is objection to the Commissioner and appeal to the Fiscal Appeal Court [Chapter 23:05] (the same forum established for classification disputes under Section 87 in the previous module). Three threads of authority guide practice:

(1) The primacy of transaction value (statutory and WTO principle). The architecture of Section 106, mirroring Article 1 of the WTO Valuation Agreement, has been consistently read — in Zimbabwe and across WTO members — as making transaction value the default that customs may displace only on stated grounds. An officer who reaches for a higher reference value without first exhausting Section 106 and following the Section 111A due-process sequence acts unlawfully. This principle is reflected in the WTO Committee's standing guidance and in the structure of the Act itself.

(2) Persuasive South African authority on valuation (non-binding). Because South Africa's Customs and Excise Act 91 of 1964 implements the same WTO Valuation Agreement, decisions of the South African Supreme Court of Appeal on the meaning of "price actually paid or payable", on the treatment of assists and royalties, and on related-party pricing are commonly cited as persuasive, non-binding authority in Zimbabwean valuation disputes. Practitioners should rely on the principle each case states rather than treating the outcome as binding in Zimbabwe.

(3) The doubt-and-reject discipline (Section 111A). The lawful exercise of value uplift turns on whether the officer had genuine grounds to doubt the declaration and whether the two-step procedure (require information; then reject and revalue) was followed. Determinations failing this test are vulnerable on appeal. The principle aligns with WTO Decision 6.1 (treatment of cases where the truth or accuracy of the declared value is in doubt), which Section 111A domesticates.

• Treating the invoice as the value. The invoice is evidence of the price actually paid or payable, not a synonym for the customs value. Omitting assists, royalties, selling commissions, container/packing costs, or freight/insurance understates the value and invites reassessment.
• Forgetting the Section 113(2) freight/insurance build-up. Declaring an FOB invoice and stopping there ignores the CIF principle. Where actuals are unavailable, the deeming provisos (15% air, 1% non-air insurance, 5%/7.5% deemed freight, 15% post) must be applied — not zero.
• Putting surtax into the import-VAT base. The most frequent computational error in Zimbabwe. Under Section 12(2) of the VAT Act, the import-VAT base is customs value plus duty, EXCLUDING surtax. Including surtax over-charges VAT; omitting customs duty under-charges it.
• Mis-handling buying commission. Buying commission is excluded (and deductible under Section 113(3)(b)) only if the agent is a genuine buying agent within the Section 104(1) proviso. A disguised seller's commission is dutiable.
• Skipping the method hierarchy. Jumping from a rejected transaction value straight to a reference value, bypassing identical/similar goods (Sections 107–108), breaches the sequence and the Section 111A procedure.
• Mis-applying the related-party rules. Assuming relationship automatically defeats transaction value (it does not — Section 106(2)), or, conversely, accepting a related-party price without testing influence.
• Fragmentation and split invoicing. Breaking a consignment to stay below the US$100 value-declaration threshold or to suppress value is a valuation-integrity offence.
• Ignoring the exchange-rate timing. Converting at a stale or wrong rate rather than the customs exchange rate at the date of entry (Section 115A) distorts the value.
• Relying on release as a clearance of value. Per Section 114, release is provisional; under-valuation surfaces on post-clearance audit within the six-year record window (Section 223), with penalties.

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.

• Valuation answers "on what amount?" — it establishes the value for duty purposes (customs value), the base on which ad valorem duty, surtax and import VAT are charged. It is the second pillar of the classification → valuation → origin → duty spine (Section 105, Customs and Excise Act [Chapter 23:02]).
• Transaction value is king (Section 106): the adjusted price actually paid or payable for goods sold for export to Zimbabwe, used wherever the four conditions are met. The five fallbacks (Sections 107–111) apply only in strict sequence, with the single permitted swap of computed-before-deductive (proviso to Section 109(1)).
• Section 113 is the arithmetic engine: add commissions (not buying commission), containers, packing, assists, royalties that are a condition of sale, and resale proceeds (113(1)); add transport and insurance to the place of importation with the deeming provisos — 15% air, 1% non-air insurance, 5%/7.5% deemed freight, 15% post (113(2)); deduct internal Zimbabwean transport and buying commission (113(3)).
• Zimbabwe values on a CIF basis and converts foreign currency at the customs exchange rate at the date of entry (Section 115A, ZIMRA Rates of Exchange for Customs Purposes, fortnightly); forex dutiable items are paid in USD (Section 115).
• The import-VAT base excludes surtax — under Section 12(2) of the VAT Act [Chapter 23:12], the base is customs value plus duty (and excise), excluding surtax, at 15.5% from 1 January 2026. This is the most error-prone line in the cascade.
• Integrity is enforced through process (Section 111A: doubt → require information → reject and revalue) and through the rule that release is never a valuation (Section 114), leaving value open to post-clearance audit within the six-year record window (Section 223).
• The seven prohibitions of Section 111(3) — no minimum, arbitrary or fictitious values, no Zimbabwean selling price of local goods, no "higher of two", etc. — are the taxpayer's shield against revenue-driven over-valuation.
• Big picture: customs valuation is where Zimbabwe's revenue protection, its WTO commitments (GATT Article VII / the WTO Valuation Agreement, domesticated by Part X), and its regional-integration agenda (SADC/COMESA/AfCFTA preference, which changes the rate but not the base) all converge. Get the value right and the entire duty/tax cascade — and the country's largest single source of border revenue leakage — comes under control.

Table 1 — The six methods of customs valuation (in order of application)

Table 2 — Section 113(2) freight & insurance deeming rules

Table 3 — The duty/tax cascade (Zimbabwe), highlighting the VAT base

Diagram — Customs valuation decision flow (ASYCUDA World)

flowchart TD
 A[Goods entered for home consumption] --> B[Is there a sale for export to Zimbabwe?]
 B -->|No| H[Use alternative methods s107 to s111 / s112 if private]
 B -->|Yes| C{Four s106 conditions met?}
 C -->|No| H
 C -->|Yes| D[Method 1 Transaction value s106]
 D --> E[Apply s113 adjustments: add assists royalties freight insurance; deduct internal transport buying commission]
 E --> F[Convert at customs rate s115A to reach VDP]
 H --> I[s107 identical] --> J[s108 similar] --> K[s109 deductive or s110 computed] --> L[s111 fall-back]
 I --> F
 J --> F
 K --> F
 L --> F
 F --> M{Risk lane}
 M -->|Green| N[Release]
 M -->|Yellow| O[Document check]
 M -->|Red| P[Physical exam]
 O --> Q[Doubt? Apply s111A: require info then reject and revalue]
 P --> Q
 Q --> R[Assess duty surtax excise then VAT on VDP plus duty excluding surtax]
 N --> R
 R --> S[Pay to ZIMRA then release]
 S --> T[Section 114 release not a valuation: post-clearance audit window s223]

Statutes & sections (Customs and Excise Act [Chapter 23:02], unless stated) - Section 86 — customs duty charged on imported goods at customs-tariff rates. - Section 87 — tariff classification (prior module) fixing the rate applied to the customs value. - Section 104 — Part X interpretation: "Agreements" (GATT Art VII / WTO Valuation Agreement), buying commission, identical/similar goods, price actually paid or payable, computed value, related persons (104(3)). - Section 105 — value for duty purposes is the transaction value (Sections 106–112); de minimis ≤ US$1 (105(2)). - Section 106 — transaction value (primary method); four conditions; related-party saving (106(2)). - Section 107 — identical goods; lowest value (107(4)); 3-month bill of entry (107(5)). - Section 108 — similar goods (107(2)–(5) applied mutatis mutandis). - Section 109 — deductive value; greatest aggregate quantity; 90-day rule; deductions (109(5)); computed-before-deductive option. - Section 110 — computed value. - Section 111 — fall-back method; seven prohibited bases (111(3)). - Section 111A — doubt as to truth/accuracy: require information, then reject and revalue. - Section 112 — valuation of goods imported privately (non-merchandise goods). - Section 113 — adjustments: additions (113(1) commissions/containers/packing/assists/royalties/resale proceeds; 113(2) transport & insurance with deeming provisos); deductions (113(3) internal transport, buying commission). - Section 114 — bill of entry / release not a determination of value. - Section 115 — payment of duty in foreign currency (USD for designated forex dutiable items). - Section 115A — rates of exchange: customs exchange rate at time of entry. - Section 116 — value for excise/surtax on locally-manufactured goods (factory cost + 25%). - Section 223 — record-keeping (six years), underpinning post-clearance audit of value. - VAT Act [Chapter 23:12] Section 6(1)(b) — charges VAT on the importation of goods; Section 12(1)–(2) — value on importation = value for customs duty purposes plus duty, excluding surtax (duty included by Finance (No. 3) Act 10 of 2009 w.e.f. 1 Jan 2010); Section 12A — deferment of import VAT on capital goods.

Regulations & Statutory Instruments - Customs and Excise General Regulations (2021 consolidation) — reg 24 declaration of value (Forms 52A/53A; exemptions incl. VDP ≤ US$100; ruling on value via Forms 54A/54B (reg 24(2))); reg 25 certificates of origin for lower rates (Forms 61/65, COMESA/SADC); returned/repaired goods valued via Sections 107–112. - COMESA — SI 244 of 2000 (preferential rates on origin). - Customs and Excise (Surtax) Regulations / Surtax Tariff Notice — surtax rates/coverage.

Tariff Notice - SI 203 of 2022 (Customs and Excise Tariff Notice 2022 / Tariff Handbook, HS 2022 edition) — tariff lines and rates cited: 6109.10.00 cotton T-shirts 40% + US$3.00/Kg; 8703.21.10 motor cars 40%; 8703.21.20 ambulances 5%; 6309.00.00 worn clothing US$5.00/Kg. Tariff lines/rates are edition-specific — confirm against the current Notice.

International instruments - GATT Article VII and the WTO Valuation Agreement (Agreement on Implementation of Article VII of the GATT) — the six-method hierarchy and the positive transaction-value standard (domesticated by Part X via the Section 104(1) definition of "the Agreements"). - WCO Technical Committee on Customs Valuation (TCCV) advisory opinions and WTO Decision 6.1 (doubt as to declared value — basis of Section 111A) — persuasive interpretive aids. - Revised Kyoto Convention (RKC) and WTO Trade Facilitation Agreement (TFA) — advance rulings, transparency, minimal intervention. - SADC Trade Protocol (Annex I, Rules of Origin); COMESA; AfCFTA — alter the duty rate applied to the customs value, not the valuation base.

Case law - On-point reported Zimbabwean customs-valuation decisions are sparse in the sources; disputes route via objection to the Commissioner and appeal to the Fiscal Appeal Court [Chapter 23:05]. Persuasive South African Supreme Court of Appeal authority on the WTO Valuation Agreement may be cited as non-binding.

ZIMRA guidance - ZIMRA Rates of Exchange for Customs Purposes (fortnightly) — the customs exchange rate under Section 115A. - ZIMRA Public Notices and Practice Notes on customs valuation, reference values, and post-clearance audit; ASYCUDA World declaration practice (Form 21/SAD, CPCs, Green/Yellow/Red risk lanes); value-declaration Forms 52A/53A and value-ruling Forms 54A/54B.