This lesson occupies the management/payment stage of the tax-debt lifecycle introduced in Introduction to Tax Debt Management (creation → management/payment → enforcement → extinguishment). It answers the most practical question in the whole course: once a liability has been created and quantified, how, when, where, in what currency, and in what order is it actually paid — and what happens the moment a payment is late, short, or misdirected. Payment is where the largest avoidable debts are born. A taxpayer who owes nothing in principle can still build a crippling debt simply by paying the right amount on the wrong date, in the wrong currency, or into a ledger that allocates it to a different liability than the one intended.

The governing architecture is Section 71 of the Income Tax Act [Chapter 23:06] — "Appointment of day and place for payment of tax" — which is the keystone. Section 71(1) declares that tax becomes due and payable on the date fixed or prescribed by or under the Act, or, where none is fixed, as notified by the Commissioner, and may be paid "in 1 sum or in instalments of equal or varying amounts" at the Commissioner's discretion. Section 71(2) arms the due date with interest at a rate fixed by the Minister by statutory instrument (the Income Tax (Rate of Interest) Notice, SI 212 of 2022), running from the due date until the debt is paid in full — subject to the celebrated special-circumstances proviso allowing the Commissioner to extend time without charging interest (MR Bank Ltd v ZIMRA 19-HH-779; Man Ltd v ZIMRA 20-HH-078). The constitutional anchor for the entire scheme is Mayor Logistics (Pvt) Ltd v ZIMRA 14-CC-007.

For provisional taxpayers — anyone with taxable income not covered by employees' tax (PAYE) — Section 72 prescribes the Quarterly Payment Dates (QPDs): four instalments of 10%, 25%, 30% and 35% of the estimated annual tax, due on or before 25 March, 25 June, 25 September and 20 December of the year of assessment (Section 72(7)). Employees' tax (PAYE) is paid by the employer under Section 73 and the Thirteenth Schedule, by the 10th of the following month. Section 72(8) contains the single most important allocation rule in the income-tax code: provisional tax paid is set off successively against (i) the tax the person is liable to pay, then (ii) any other tax or amount due and payable, with any excess refunded — the statutory ancestor of the modern Single Account "oldest-debt-first" allocation.

On the VAT side, Section 28 of the VAT Act [Chapter 23:12] requires every registered operator to furnish a return and pay the tax within a period that the Finance (No. 2) Act 7 of 2024 shortened from the 25th day to the 15th day of the month following the tax period, with effect from 1 January 2025 — one of the most consequential recent payment-law changes, and one that currently conflicts with the Zimbabwe Tax Compliance Calendar, which still shows the 25th. Section 38 prescribes the manner of payment and the currency-of-payment rule (tax on a supply paid for in foreign currency must be paid to ZIMRA in that foreign currency — Delta Beverages 23-HH-577; Inamo Investments 22-HH-672 / 23-SC-096; Prosperous Days 21-HH-024), backed by the double-tax civil penalty in Section 38A. Section 39 is the default engine: late VAT attracts a penalty equal to 100% of the tax (Section 39(2)(a)(i)) plus interest at the prescribed rate for each month or part of a month (Section 39(2)(a)(ii)) — the rate being set by the Fifth Schedule to the VAT (General) Regulations, SI 273/03, as substituted by SI 25/2025 (gazetted 19 March 2025): bank policy rate + 5% for local-currency debt and a flat 10% for foreign-currency debt. Section 39(5) supplies the remission safety valve (no State loss / no operator benefit / no intent — VSL 19-HH-023, E.J 19-HH-528, R 19-HH-792, G 22-HH-011).

The modern payment channel is statutory too: Section 4B of the Finance Act [Chapter 23:04] (inserted by the Finance (No. 2) Act 10 of 2022) lets a taxpayer pay any revenue through an approved financial intermediary (a bank holding a ZIMRA account) and obliges that intermediary to credit the Consolidated Revenue Fund within 24 hours (shortened from 48 hours by Act 7 of 2024 w.e.f. 1 January 2025), failing which the intermediary — not the taxpayer — pays interest of 15% (USD) or bank policy rate + 5% (ZWL). In practice payment happens on the ZIMRA Self-Service Portal (SSP) / TaRMS, through the Payments module (credit card or e-banking) into the taxpayer's Single Account — a unified USD-and-ZiG ledger that allocates money to the oldest debt first within a tax type, then by tax-type priority, which is why a payment "for VAT" can silently settle an old PAYE shortfall and leave the VAT live.

Two iron rules run through the lesson. First, the obligation to pay is not suspended by a dispute — pay-now-argue-later (Income Tax Act Section 69; VAT Act Section 36), established in Mayor Logistics. Second, currency follows the liability: USD and ZiG balances do not net against each other — a USD-stream tax cannot be discharged out of a ZiG credit. By the end you will be able to (1) determine the exact due date for every major tax head; (2) compute QPDs, PAYE, VAT and the interest/penalty that bite on late payment, line by line in USD; (3) choose and operate the correct payment channel; (4) predict how the Single Account will allocate a payment and protect a client from misallocation; and (5) recognise the audit and governance flags that surround payment.

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Every tax system has three moving parts: a rule that creates liability, a process that quantifies it, and a discipline that collects it. The first two were the subject of earlier lessons — Creation of Tax Debt (when liability arises) and Tax Assessments and Their Role (how it is quantified). This lesson is about the third, and it is where theory meets the bank account. A liability that is correctly created and correctly assessed still does the fiscus no good until the money actually reaches the Consolidated Revenue Fund — and it does the taxpayer real harm the instant it is paid wrongly.

Payment is deceptively simple to describe and surprisingly easy to get wrong. The reason is that "paying your tax" is not one act but a cluster of distinct obligations, each with its own due date, its own form, its own channel, and its own default penalty: PAYE on the 10th, withholding taxes on the 10th, VAT on the 15th (since 2025), provisional income tax on the QPD calendar, the annual income-tax balance four months after year-end, capital gains tax within 30 days of a disposal. A medium-sized company can have a dozen separate payment deadlines in a single month. Miss any one and the law does not wait to be asked: interest accrues automatically and, for VAT, a 100% penalty attaches by operation of law.

The context that makes this lesson urgent in Zimbabwe specifically is multi-currency and digitisation. Since the re-introduction of foreign currency as legal tender alongside the local unit (ZWL, then ZiG), the law has insisted that tax follows the currency of the underlying transaction — you cannot earn in USD and settle the tax in ZiG. And since the rollout of TaRMS and the Self-Service Portal, payment is mediated by a Single Account ledger whose automated allocation logic can defeat a taxpayer's intentions. Both features are recent, both are examinable, and both are where ZIMRA audit interest — and avoidable client losses — concentrate.

Two foundational distinctions frame everything that follows.

First — "due" versus "payable" versus "paid." A liability is due when the charging section fixes it (the taxable event occurs). It becomes payable when Section 71(1) attaches a date to it. It is paid only when the money is received and allocated by ZIMRA. The gap between "payable" and "paid" is where interest lives. The whole of payment law is about closing that gap on time and in the right place.

Second — principal versus the secondary charges. Recall the four-component anatomy of a tax debt from Identification and Classification of Tax Debt: principal (the tax itself), interest (compensatory, automatic), additional tax / penalty (punitive), and civil penalties (fixed procedural charges). Payment law is the discipline that keeps a debt to its principal alone. Every day of delay converts a clean principal liability into a layered debt — and, as Write-Offs and Remission of Tax Debt established, only the secondary layers are ever remissible; the principal is immovable. Paying on time is therefore not merely good housekeeping; it is the only reliable way to ensure you never owe more than the tax itself.

B1. Income Tax Act [Chapter 23:06] — Section 71: day, place, manner and interest

Section 71 is headed "Appointment of day & place for payment of tax." It is the master payment provision for income tax and, through cross-references, for the schedule-based taxes (PAYE, withholding taxes) as well.

Section 71(1) provides that tax "shall become due and payable on such date and shall be paid on or before such days and at such places as are fixed or prescribed by or under this Act or, where no such time or place is so fixed or prescribed, as may be notified by the Commissioner, and may be paid in 1 sum or in instalments of equal or varying amounts as may be determined by the Commissioner, having regard to the circumstances of the case." A proviso preserves the taxpayer's "right to pay his tax through the post" — a now-anachronistic survival from a pre-electronic era, but still live law worth noting. This single subsection does four things: it fixes when (the prescribed date), where (the prescribed place), how much at a time (one sum or instalments), and who decides instalments (the Commissioner). The instalment power in Section 71(1) is the statutory root of the payment-plan / instalment-arrangement regime examined in Payment Plans and Instalments. The provision was last amended by Act 18/2000 and is anchored constitutionally by Mayor Logistics (Pvt) Ltd v ZIMRA 14-CC-007.

Section 71(2) is the interest engine. "If tax is not paid on or before such days … interest, calculated at a rate to be fixed by the Minister, by statutory instrument, shall be payable on so much of the tax … as from time to time remains unpaid … beginning on the date specified … as the date on which the tax … shall be paid and ending on the date the tax … is paid in full." The instrument is the Income Tax (Rate of Interest) Notice, SI 212 of 2022, gazetted 19 December 2022 and backdated to 1 December 2022.

The crucial proviso to Section 71(2) reads: "in special circumstances the Commissioner may extend the time for payment of the tax without charging interest" (amended by Act 10/2003). This is a de facto interest remission and is the most valuable single discretion a distressed income-tax debtor can invoke. Its limits were drawn in MR Bank Ltd v ZIMRA 19-HH-779 — deliberate misapplication of funds is not a "special circumstance." Man Ltd v ZIMRA 20-HH-078 is the companion authority on Section 71(2) interest.

Section 71(3) closes a gap: where a person responsible for paying tax under the Ninth, Thirteenth, Fifteenth, Sixteenth, Seventeenth or Eighteenth Schedule (i.e. PAYE and the various withholding-tax regimes) fails to pay within the time the Schedule allows, interest at the Minister's SI rate runs from the day after the Schedule's deadline until paid (inserted by Act 10/2003). This means schedule-based taxes carry their own interest clock independently of Section 71(2).

B2. Income Tax Act — Section 72: provisional tax and the QPD calendar

Section 72 governs provisional tax — the mechanism by which income tax on non-PAYE income is collected during the year of assessment rather than in a lump at the end. Its definitions matter: "provisional tax" is the amount a person estimates will be his tax liability for the year after excluding employees' tax already withheld; a "quarterly payment date" is a day fixed under the section by which an instalment must be paid; the "relevant year of assessment" is the year in which the income accrued.

Section 72(2) obliges every person whose taxable income includes an amount not subject to PAYE to pay provisional tax in four quarterly instalments. Redan Petroleum (Pvt) Ltd v ZIMRA 23-HH-637 confirms the payments are made during the year, not bunched at year-end. Section 72(3) requires the taxpayer to submit, with each payment, an estimate of total taxable income (the ITF 12B return). If no estimate is submitted, Section 72(4) lets the Commissioner estimate, and that estimate is "final and conclusive"; Section 72(5) lets the Commissioner increase an inadequate estimate, again "final and conclusive"; Section 72(6) makes those discretions subject to objection and appeal.

Section 72(7) fixes the instalments and dates:

• 1st instalment — 10% of the provisional tax payable — on or before 25 March;
• 2nd instalment — 25% — on or before 25 June;
• 3rd instalment — 30% — on or before 25 September;
• 4th instalment — 35% — on or before 20 December.

These four percentages sum to 100%, so on the statute's own terms the entire year's provisional tax is paid by 20 December. A proviso (inserted by Finance (No. 2) Act 10 of 2022) adjusts the dates for taxpayers whose accounting year-end is not 31 December (under Section 37(13)).

Section 72(8) is the allocation rule: as soon as the tax payable is determined, the Commissioner shall set off provisional tax paid, successively, against (i) "the tax the person is liable to pay" and then (ii) "any other tax or amount due and payable to the Commissioner-General by the person," and refund any balance. This is the statutory blueprint for the Single Account's oldest-first allocation: provisional tax is not ring-fenced to the year it was paid for; it can be swept onto other live liabilities. Section 72(9)–(10) apply Section 71(2) interest to unpaid or short-paid instalments — a deficit on a quarterly instalment is "deemed to be an amount of provisional tax remaining unpaid." Section 72(11) lets the Commissioner waive interest where the taxpayer was, through special circumstances, unable to pay (SZ (Pvt) Ltd v ZIMRA 20-HH-142), or underestimated by not more than 10% or because of a rate increase or "other sufficient cause." Section 72(13)(a) exempts taxpayers below a prescribed taxable-income threshold; Section 72(13)(b) lets the Commissioner fix different dates; and Section 72(14) (inserted by the Finance Act 2017) lets a qualifying small or medium enterprise pay provisional tax monthly, one month in advance.

B3. Income Tax Act — Section 73: payment of employees' tax (PAYE)

Section 73 routes employees' tax through the Thirteenth Schedule. Section 73(1) makes PAYE payable on remuneration as defined in paragraph 1 of that Schedule; Section 73(2) requires payment of amounts withheld under paragraph 3 "at such place as may be notified by the Commissioner"; and Section 73(3) imposes interest (at the Minister's SI rate) where PAYE is not paid in full within the Schedule's prescribed period, "unless the Commissioner, having regard to the circumstances of the case, otherwise directs." The practical deadline — confirmed by the Zimbabwe Tax Compliance Calendar — is the 10th of the month following the month of the remuneration, on Form P2. PAYE is a trust-type liability: the employer collects the employee's tax and holds it for the State; non-remittance is therefore treated with particular severity.

B4. Income Tax Act — Sections 74, 76 and 77: who pays, de minimis, and the deemed debt

Section 74 ("Persons by whom tax is payable") fixes liability on the representative taxpayer for income in his representative capacity (Section 74(1)(a)) and on the person to whom income accrues otherwise (Section 74(1)(b)); Section 74(2) preserves a right of recovery between persons where an amount is included in one taxpayer's income but economically another's. Representative-taxpayer liability (Sections 53–58) is developed in Tax Debt Enforcement Powers and Special Tax Debt Situations.

Section 76 ("No tax payable in certain circumstances") is the de minimis rule: no tax is payable for a year of assessment if the person's liability (or aggregate of liabilities) is less than US$0.50 or such other amount as the Minister fixes (Section 76(1)); and Section 76(2) relieves an individual of further income tax where the year's liability exceeds the PAYE credit by less than US$250 (or the fixed amount). These thresholds spare both taxpayer and ZIMRA the cost of chasing trivial balances.

Section 77(1) ("Recovery of tax") is the keystone that converts an unpaid liability into an enforceable debt: "Any tax shall, when it becomes due or is payable, be deemed to be a debt due to the State and shall be payable to the Commissioner in the manner and at the place prescribed, and may be sued for and recovered by action … in any court of competent jurisdiction." The words "in the manner and at the place prescribed" tie recovery back to the payment rules in Sections 71–73 — paying in the prescribed manner and place is precisely what discharges the deemed debt. (Section 77's recovery and anti-phoenix machinery is the subject of Civil Recovery Through Courts and Tax Debt Enforcement Powers.)

B5. Income Tax Act — Section 69: pay-now-argue-later

Section 69 ("Payment of tax pending decision on objection and appeal") provides that the obligation to pay tax is not suspended by an objection or appeal unless the Commissioner so directs. This is the income-tax pay-now-argue-later rule, constitutionally upheld in Mayor Logistics (Pvt) Ltd v ZIMRA 14-CC-007 and examined fully in Tax Disputes and Debt Collection. Its payment-law consequence is blunt: a dispute does not stop the interest clock. A taxpayer who withholds payment pending an objection, and loses, pays the principal plus interest for the whole disputed period.

B6. VAT Act [Chapter 23:12] — Sections 27 and 28: tax periods and the payment deadline

Section 27 defines the tax periods. Category A operators have two-month periods ending on the last day of January, March, May, July, September and November; Category B have two-month periods ending February, April, June, August, October and December; Category C have one-month periods; Category D have customised periods the Commissioner approves. (The VAT registration threshold referenced in Section 27 is US$240,000 of annual taxable supplies, increased by successive Finance Acts.)

Section 28 ("Returns and payments of tax") is the operative VAT payment provision. Section 28(1) requires every registered operator, within the period ending on the 15th day of the first month commencing after the end of a tax period (or, where the period ends mid-month, by the last day of the month), to (a) furnish a return in the prescribed form (the VAT 7) and (b) calculate and pay the tax payable, or calculate any refund due. The 15th-day deadline is the product of a precise legislative history worth stating in full, because it is a textbook old-versus-new contrast and a current source conflict:

• originally 5 days, extended to 10 days (Finance (No. 3) Act 10 of 2009, w.e.f. 1 January 2010);
• extended to 15 days (Act 3 of 2010, w.e.f. 1 September 2010);
• extended to 20 days (Act 5 of 2010, w.e.f. 1 January 2011);
• extended again — to the 25th day — by the Finance (No. 2) Act 9 of 2011, w.e.f. 1 January 2012; and
• shortened from the 25th day back to the 15th day by Section 33 of the Finance (No. 2) Act 7 of 2024, with effect from 1 January 2025.

So, for tax periods from 1 January 2025, VAT returns and payment are due by the 15th of the following month, not the 25th.

Section 28(2) requires a return whether or not tax is payable — the basis of the nil-return obligation (ZIMRA v Packers International (Pvt) Ltd 16-SC-028). Section 28(3) lets the Commissioner, subject to Section 38, extend the time to furnish or pay.

B7. VAT Act — Section 38: the manner and currency of payment

Section 38 ("Manner in which tax shall be paid") requires the tax to be paid in full within the time allowed by Section 13 (imported services), Section 28 or Section 29, whichever applies (Section 38(1)). Where, "due to circumstances beyond the control" of the operator, the amount cannot be accurately calculated in time, the Commissioner may accept a deposit equal to the estimated liability (Section 38(2)), treated as a provisional payment with later top-up or refund (Section 38(3)).

The heart of Section 38 is the currency-of-payment rule in Section 38(4) and (4a): where an operator receives tax in foreign currency on a supply, it must pay that amount to ZIMRA in foreign currency (Section 38(4)(a)); tax on imported goods is likewise payable in foreign currency (Section 38(4)(b)). Section 38(4a), inserted by the Finance Act 1 of 2019 (w.e.f. 1 January 2019), states it sharply: if the price was paid in foreign currency, the operator shall pay the tax in that foreign currency; if paid in local legal tender, the operator may pay in that tender or in foreign currency. "Foreign currency" is defined to include the Euro, British pound, US dollar, SA rand, Botswana pula and currencies under the Exchange Control (General) Order. Section 38(8) lets the Commissioner require the USD equivalent where another foreign currency is tendered. The rule is heavily litigated — Delta Beverages (Pvt) Ltd v ZIMRA 23-HH-577, Inamo Investments (Pvt) Ltd v ZIMRA 22-HH-672 (on appeal 23-SC-096), and Prosperous Days Investments v ZIMRA 21-HH-024.

B8. VAT Act — Section 38A: the double-tax civil penalty

Section 38A (inserted by the Finance Act 1 of 2019) enforces Section 38(4a). On a breach, the Commissioner — after giving at least 7 days' right of reply — serves a Section 31 assessment of double the foreign-currency tax, payable in the foreign currency concerned (the "primary civil penalty"). Continued default after 7 days of a 181-day window is an offence (fine up to level 10 or up to six months' imprisonment, or both). The penalty proceeds form part of the Consolidated Revenue Fund. The lesson for payment practice is stark: mis-currencying a VAT payment is not a small slip — it can double the bill.

B9. VAT Act — Section 39: penalty and interest for late payment

Section 39 is the VAT default engine. Where an operator required to pay under Section 28(1) fails to pay within the period allowed, he must, in addition to the tax, pay:

• (Section 39(2)(a)(i)) a penalty equal to the amount of the tax — i.e. 100%; and
• (Section 39(2)(a)(ii)) interest at the prescribed rate "for each month or part of a month" reckoned from the first day of the month following the month in which the payment period ended.

The same penalty-plus-interest formula applies to special returns under Section 29 (Section 39(3)) and to additional tax under Section 66 (Section 39(4), interest only). Section 39(5) is the remission valve: the Commissioner may remit penalty or interest, in whole or in part, where the default caused no financial loss to the State, gave the operator no financial benefit, and was not due to an intent to avoid or postpone the tax (VSL (Pvt) Ltd & 3 ors v ZIMRA 19-HH-023; V v ZIMRA 19-HH-643; E.J (Pvt) Ltd v ZIMRA 19-HH-528; R (Pvt) Ltd v ZIMRA 19-HH-792; G (Pvt) Ltd v ZIMRA 22-HH-011). Section 39(6) provides that a person who, owing no tax, nevertheless fails to file, contravenes Section 62(2) and may compromise under Section 65.

The prescribed rate is the Fifth Schedule to the VAT (General) Regulations, SI 273/03, substituted successively (SI 75/2010; SI 283/2019; SI 53/2021 — which set 25%; and most recently SI 25/2025, gazetted 19 March 2025). Under SI 25/2025:

• local-currency unpaid VAT — interest = bank policy rate (as revised from time to time) + 5%;
• foreign-currency unpaid VAT — interest = 10% (w.e.f. 1 January 2020).

B10. VAT Act — Section 36: pay-now-argue-later

Section 36 ("Payment of tax pending decision on objection and appeal") is the VAT twin of income-tax Section 69: the obligation to pay VAT "shall not, unless the Commissioner so directs, be suspended" by an objection or appeal. Same consequence — a VAT dispute does not stop the Section 39 clock.

B11. Finance Act [Chapter 23:04] — Section 4B: payment through financial intermediaries

Section 4B ("Prompt remittance of revenues paid through financial intermediaries"), inserted by the Finance (No. 2) Act 10 of 2022, modernises the channel of payment. Where the Commissioner-General holds an account with a financial intermediary (an "approved financial intermediary" — a bank registered under the Banking Act [Chapter 24:20]), a taxpayer may use that intermediary to pay any "taxes, duties, fees, levies, charges, penalties, fines or any other moneys" due under any revenue Act (Section 4B(2)). The intermediary must remit the full amount so that the Consolidated Revenue Fund is credited within 24 hours of payment (Section 4B(3) — shortened from 48 hours by Act 7 of 2024, w.e.f. 1 January 2025). An intermediary that delays without valid reason is liable to the Commissioner for interest of 15% (USD) or bank policy rate + 5% (ZWL) on the un-remitted amount (Section 4B(4)). The practical significance: when a taxpayer pays through a bank that participates in the scheme, the date of payment to the bank is what counts for the taxpayer; the remittance-timing risk shifts to the intermediary.

C1. The five questions every payment must answer

A correct tax payment is the simultaneous correct answer to five questions. Get any one wrong and a debt can result even where the principal is right.

1. How much? — the assessed or self-assessed amount, plus any instalment percentage (QPDs) or schedule fraction (PAYE).
2. When? — the statutory due date for that head (PAYE 10th; VAT 15th; QPDs 25 Mar/Jun/Sep, 20 Dec; annual income tax 30 Apr; CGT within 30 days).
3. Where / through what channel? — the prescribed place (Section 71(1)); in practice the SSP Payments module, by credit card or e-banking, or through an approved financial intermediary (Finance Act Section 4B).
4. In what currency? — the currency of the underlying transaction (VAT Section 38(4a); and, for income tax, the currency in which the income arose). USD and ZiG do not net.
5. Against what liability? — how the payment will be allocated by the Single Account (oldest-first within tax type, then by tax-type priority). The taxpayer's intention does not control allocation; the ledger's rules do.

The lesson's organising insight is that questions 4 and 5 are the ones practitioners forget — and they are the ones that turn a paid taxpayer into a debtor.

C2. Due dates: the calendar as law

Due dates are not administrative conveniences; they are fixed or prescribed by or under the Act (Section 71(1)) and the moment they pass, interest runs (Section 71(2)/(3); VAT Section 39). The default rule of thumb from the compliance calendar is a useful mnemonic: every monthly remittance is due on the 10th of the following month, except VAT (now the 15th); every quarterly remittance follows the QPD calendar; annual returns are due four months after year-end. The monthly-10th family includes PAYE (P2), the combined withholding taxes (REV 5), IMTT (REV 5B), presumptive taxes (REV 5A), mining royalties (REV 5C) and digital-services WHT. The two-monthly/monthly VAT family runs on the 15th (statutory, from 2025). Provisional income tax runs on 25 March, 25 June, 25 September and 20 December; the annual self-assessment (ITF 12C) and individual return (ITF 1) on 30 April for a 31 December year-end. Capital gains tax is event-driven — within 30 days of a disposal (CGT 1).

C3. Allocation: the Single Account and the oldest-debt-first rule

The most counter-intuitive concept in modern Zimbabwean payment practice is that you do not pay a specific assessment — you pay the Single Account. Under the SSP/TaRMS architecture, every taxpayer has one unified ledger across all revenue heads, recorded separately in USD and ZiG. A payment lands in that ledger and is then allocated by ZIMRA's rules — typically the oldest debt first within a tax type, then by tax-type priority. This is the administrative expression of the statutory set-off in Section 72(8) ("any other tax or amount due and payable").

The consequence is the misallocation trap: a company that intends a payment to clear its current VAT, but which carries an older unpaid PAYE shortfall, may find the money swept onto the PAYE debt, leaving the VAT live and accruing the 100% penalty plus interest. The defence is procedural and disciplined: (a) keep every tax head current so there is no older debt to absorb a payment; (b) reconcile the Single Account monthly using the Taxpayer Accounting Summary Report; and (c) where a payment has been misallocated, lodge a request to re-allocate through Case Management.

C4. Currency segregation: USD and ZiG are separate ledgers

The Single Account holds two non-fungible columns. A USD-stream liability cannot be discharged from a ZiG credit, and vice versa. This flows from the currency-of-payment rule (VAT Section 38(4a); and the broader requirement that tax follow the currency of the income). A taxpayer sitting on a ZiG refund credit but owing USD VAT is still a USD debtor — the credit does not help. Practitioners must therefore monitor two balances per head, not one, and plan currency liquidity accordingly.

C5. The payment channels, step by step

There are, in practice, three channels:

• SSP Payments module — credit card. Direct online payment in USD or ZiG.
• SSP Payments module — e-banking. The portal lists participating banks; the taxpayer initiates the payment from the bank's platform and it posts to the Single Account.
• Approved financial intermediary (Finance Act Section 4B). Payment through a bank holding a ZIMRA account; the bank must credit the CRF within 24 hours, and bears the interest risk if it delays.

Whichever channel is used, the payment reference / Business Partner (BP) number must be correct so the money reaches the right taxpayer's Single Account. After payment, the taxpayer can verify posting under Payments → Payment History and Single Account Transactions, and confirm the net position under Taxpayer Accounting → Summary Report.

C6. The interest mechanics — how the clock actually counts

Interest is compensatory, not punitive: it prices the State's lost use of money. Three features recur:

• It runs from the due date (income tax, Section 71(2)/(3)) or from the first day of the month following the late month (VAT, Section 39(2)(a)(ii)).
• For VAT it is charged "for each month or part of a month" — meaning one day into a new month counts as a whole month. A VAT debt paid on the 2nd of a month is charged the same interest as one paid on the 30th of that month.
• The rate is period-specific and instrument-set: income tax by SI 212/2022; VAT by the Fifth Schedule (SI 25/2025) — policy rate + 5% local, 10% foreign.

Because VAT interest is part-month-rounded, paying even a few days into a month is as expensive as paying the whole month late — a strong reason to settle before month-end if a deadline has already slipped.

C7. Deposits, provisional payments and the Section 38(2) safety route

Where a VAT liability genuinely cannot be quantified in time (e.g. a complex period under audit), Section 38(2) allows a deposit of the estimated tax, treated as a provisional payment (Section 38(3)). This is a legitimate way to stop the clock on the estimated principal while the exact figure is settled — paying a good-faith estimate is far cheaper than letting the full amount accrue penalty and interest. It is the VAT analogue of the income-tax instalment power in Section 71(1).

D1. Individual — employee (PAYE handled by the employer)

Scenario. Rumbidzai is employed by Highfield Engineering (Pvt) Ltd, earning USD 2,500 a month. Her employer withholds PAYE under the Thirteenth Schedule and remits it on Form P2 by the 10th of the following month (Section 73). For most employees, the employer carries the payment obligation — the employee's only payment touchpoint is the annual reconciliation.

If Rumbidzai has no other income, her PAYE is a final-ish settlement and, by Section 76(2), no further income tax is payable if her annual liability exceeds the PAYE credit by less than US$250. If she does have side income (say USD 9,000 of consultancy), that portion is not covered by PAYE and pushes her into the provisional-tax regime (D2).

Employer-side payment failure. Suppose Highfield withholds Rumbidzai's PAYE but pays the December P2 (USD 6,800 total payroll PAYE) on 15 January instead of the 10th:

Line	Amount (USD)
PAYE withheld (principal)	6,800.00
Interest under Section 73(3) (Minister's SI rate, from 11 Jan)	rate per SI 212/2022
Exposure to additional tax / offence for non-remittance of trust money	per Thirteenth Schedule

The teaching point: PAYE is the employee's money held in trust. Late remittance exposes the employer to interest (Section 73(3)) and, for outright non-remittance, to the penalties examined in Tax Debt Enforcement Powers. The employee is protected — she gets credit for tax withheld whether or not the employer remitted (Taxpayer Account Management).

D2. Individual — sole trader (provisional tax / QPDs)

Scenario. Tendai runs a hardware business as a sole trader. For the 2025 year of assessment he estimates taxable income giving an annual tax of USD 20,000. As a provisional taxpayer (Section 72(2)) he pays four QPDs (Section 72(7)):

QPD	%	Amount (USD)	Due
1st	10%	2,000.00	25 Mar 2025
2nd	25%	5,000.00	25 Jun 2025
3rd	30%	6,000.00	25 Sep 2025
4th	35%	7,000.00	20 Dec 2025
Total	100%	20,000.00	by 20 Dec 2025

Short payment. Suppose Tendai pays only USD 4,000 of the 2nd QPD (USD 5,000 due) on 25 June. The USD 1,000 deficit is, by Section 72(10), "deemed to be an amount of provisional tax remaining unpaid" from 25 June, and interest under Section 71(2) runs on the USD 1,000 from 26 June until paid (rate per SI 212/2022 — VERIFY). If the underpayment arose from an underestimate of not more than 10% of the instalment, or from special circumstances, Tendai can apply under Section 72(11) for the interest to be waived (SZ (Pvt) Ltd 20-HH-142).

Year-end set-off (Section 72(8)). When Tendai files his ITF 12C on 30 April 2026 and his final tax for 2025 is determined at, say, USD 19,200, the Commissioner sets off the USD 20,000 provisional tax paid against (i) the USD 19,200 final tax and then (ii) any other amount due; the USD 800 excess is refundable (or, if Tendai owes an older VAT or PAYE balance, swept onto that under the "any other tax or amount due" limb — the statutory misallocation trap).

D3. SME — VAT, correct currency, on time

Scenario. Sadza Foods (Pvt) Ltd is a Category C (monthly) VAT operator. For the April 2025 tax period it has output VAT of USD 18,000 and input VAT of USD 7,000, all on USD-denominated supplies. Net VAT payable = USD 11,000.

Line	Amount (USD)
Output VAT (April 2025)	18,000.00
Less input VAT	(7,000.00)
Net VAT payable	11,000.00
Due date (Section 28(1), from 2025)	15 May 2025
Currency (Section 38(4a) — supplies paid in USD)	USD

Paid in USD on or before 15 May 2025, Sadza owes exactly USD 11,000 — no penalty, no interest. The two things Sadza must get right are the 15th (not the old 25th) and USD (not ZiG).

D4. SME — VAT paid late, in foreign currency

Scenario. Same Sadza Foods, but the USD 11,000 April VAT is paid on 20 July 2025 — the period was due 15 May, so payment falls in the third month after the deadline month (the deadline month being May; interest runs from 1 June; June, July = into the second part-month at minimum; using the statutory "each month or part of a month" from 1 June to 20 July inclusive gives two month-units).

VAT interest is computed on the house basis used across this course: the Fifth-Schedule forex rate of 10% per annum, accrued per month or part of a month (i.e. ×(month-units)/12):

Line	Computation	Amount (USD)
Principal VAT	—	11,000.00
Penalty, Section 39(2)(a)(i) (100%)	11,000 × 100%	11,000.00
Interest, Section 39(2)(a)(ii) (10% p.a. forex, 2 month-units)	11,000 × 10% × 2/12	183.33
Total now payable		22,183.33

The principal doubled the instant payment slipped past 15 May — the 100% penalty is automatic. The interest is comparatively small but is part-month-rounded: paying on 1 July versus 31 July costs the same. Sadza's only relief is Section 39(5) remission of the penalty/interest if it can show no State loss, no benefit, and no intent — a high bar (VSL, E.J, R, G). If the interest figure is instead read as the literal 10% per month (an interpretation some take of the Fifth Schedule wording), the interest would be 11,000 × 10% × 2 = USD 2,200; the conservative per-annum reading is used above, with the alternative flagged.

D5. SME — the wrong-currency disaster (Section 38A)

Scenario. Borrowdale Bakers (Pvt) Ltd collects its VAT from customers in USD but, short of USD liquidity, pays the USD 9,000 April VAT to ZIMRA in ZiG. This breaches Section 38(4a) (USD-collected tax must be paid in USD). After a 7-day right of reply, the Commissioner serves a Section 31 assessment under Section 38A for the primary civil penalty of double the tax in USD:

Line	Amount (USD)
VAT collected in USD (principal)	9,000.00
Primary civil penalty, Section 38A (double)	18,000.00
Exposure	27,000.00 (and the ZiG paid does not discharge the USD liability)

The ZiG payment does not net against the USD debt (currency segregation). Borrowdale is now exposed to three times what it would have paid had it simply paid USD 9,000 in USD. This is the single most expensive payment mistake in the VAT code.

D6. Large corporate / multinational — multi-head payment, channel and set-off

Scenario. Zambezi Holdings (Pvt) Ltd, a large group, in a single month must pay: PAYE USD 140,000 (10th), combined WHT USD 30,000 (10th), VAT USD 220,000 (15th), and the 3rd QPD of provisional income tax USD 600,000 (25 Sep). It pays through an approved financial intermediary under Finance Act Section 4B.

• Channel risk shifts. Because Zambezi pays through a participating bank, the date it pays the bank is the operative date; the bank must credit the CRF within 24 hours or itself pay interest (15% USD / policy+5% ZWL) — the timing risk is the intermediary's, not Zambezi's. Zambezi should nonetheless keep proof of the payment instruction and confirm posting on the Single Account.
• Currency discipline. Each head is paid in the currency of the underlying liability; USD-stream taxes in USD, any ZiG-stream taxes in ZiG, on two separate ledgers.
• Set-off / allocation (Section 72(8)). If Zambezi carries any older arrear on any head, a payment can be swept onto it first. With sums this large, a single misallocation can leave a current head materially unpaid and accruing the VAT 100% penalty — so the group reconciles the Single Account the same day and lodges re-allocation requests immediately if money lands wrong.
• Pay-now-argue-later. Zambezi is disputing part of the VAT assessment, but Section 36 means it must pay now; if it withholds and loses, interest runs on the disputed principal for the whole period.

D7. SME — the monthly-provisional-tax election (Section 72(14))

Scenario. A qualifying small or medium enterprise with uneven cash flow finds the lumpy 30%/35% QPDs in September and December painful. Under Section 72(14) it applies to pay provisional tax monthly, one month in advance, smoothing the burden into twelve smaller payments. This is a genuine cash-flow tool that keeps the SME current and avoids the Section 72(10) deficit-interest trap.

Mayor Logistics (Pvt) Ltd v ZIMRA 14-CC-007 (Constitutional Court). The constitutional anchor of the entire payment-and-recovery scheme. It upheld the pay-now-argue-later principle (Section 69 / VAT Section 36) and confirmed the legitimacy of the Section 71 due-date-and-instalment machinery. Principle: the obligation to pay is constitutionally valid and is not suspended by a dispute unless the Commissioner directs.

MR Bank Ltd v ZIMRA 19-HH-779. Tested the Section 71(2) special-circumstances proviso (extension of time without interest). The court held that deliberate misapplication of funds — choosing to use tax money for other purposes — is not a "special circumstance." Principle: the interest-free-extension discretion is for genuine, blameless inability, not cash-flow choices.

Man Ltd v ZIMRA 20-HH-078. Companion authority on Section 71(2) interest on unpaid income tax, confirming the automatic accrual of interest from the due date.

Redan Petroleum (Pvt) Ltd v ZIMRA 23-HH-637. Confirmed that provisional tax under Section 72 is paid in quarterly instalments during the year, not at year-end. Principle: the QPD calendar is mandatory and time-specific.

SZ (Pvt) Ltd v ZIMRA 20-HH-142. On the Section 72(11) interest-waiver discretion for provisional-tax shortfalls arising from special circumstances or an underestimate of not more than 10%. Principle: there is a structured relief route for honest QPD underpayment, but it must be justified.

ZIMRA v Packers International (Pvt) Ltd 16-SC-028 (Supreme Court). Confirmed that a return must be filed even where no tax is payable (VAT Section 28(2)). Principle: the nil return is itself an obligation; a zero balance does not excuse non-filing.

Delta Beverages (Pvt) Ltd v ZIMRA 23-HH-577; Inamo Investments (Pvt) Ltd v ZIMRA 22-HH-672 / 23-SC-096; Prosperous Days Investments v ZIMRA 21-HH-024. The currency-of-payment line under Section 38(4)/(4a). Principle: VAT (and tax generally) on a foreign-currency supply must be paid to ZIMRA in that foreign currency; paying in local tender does not discharge a foreign-currency liability and risks the Section 38A double penalty.

The Section 39(5) remission line — VSL (Pvt) Ltd & 3 ors v ZIMRA 19-HH-023; V v ZIMRA 19-HH-643; E.J (Pvt) Ltd v ZIMRA 19-HH-528; R (Pvt) Ltd v ZIMRA 19-HH-792; G (Pvt) Ltd v ZIMRA 22-HH-011. These cases map the boundaries of penalty/interest remission for late VAT payment: relief requires no State loss, no operator benefit, and no intent to avoid or postpone. Principle: the 100% penalty and interest are remissible only on the strict tripartite test — and the principal never is.

1. Using the old 25th VAT deadline. Since 1 January 2025 the statutory VAT deadline is the 15th (Section 28(1), as amended by Act 7 of 2024). Diarising the 25th — as many calendars and templates still do — risks a late payment that triggers the automatic 100% Section 39 penalty. (Note the live conflict with the compliance calendar; confirm against the latest Public Notice, but do not assume the 25th.)

2. Paying in the wrong currency. USD-collected VAT paid in ZiG breaches Section 38(4a) and exposes the operator to the Section 38A double-tax civil penalty — and the wrong-currency payment does not even discharge the debt (currency segregation). Always match the payment currency to the currency of the underlying supply or income.

3. Assuming a payment settles the liability you intended. Payments hit the Single Account and are allocated oldest-debt-first. A "VAT payment" can clear an old PAYE arrear, leaving the VAT live. Reconcile the Single Account monthly and keep every head current.

4. Treating a dispute as a payment holiday. Pay-now-argue-later (Section 69 / Section 36) means the interest clock runs throughout an objection. Withholding payment pending a dispute, and losing, costs principal plus interest for the whole period.

5. Forgetting that VAT interest is part-month-rounded. "Each month or part of a month" (Section 39) means one day into a month is a full month's interest. If a deadline has already slipped, pay before month-end to avoid tipping into another whole month-unit.

6. Short-paying a QPD and ignoring it. A QPD deficit is deemed unpaid provisional tax (Section 72(10)) and accrues interest from the quarter date. Apply for Section 72(11) waiver where the shortfall was an honest ≤10% underestimate or special circumstance — but do not assume it is automatic.

7. Not filing a nil return. A zero balance still requires a return (Section 28(2); Packers). Non-filing is a separate contravention regardless of whether tax is owed.

8. Relying on a ZiG credit to cover a USD debt. The ledgers do not net. A ZiG refund credit leaves a USD liability fully live.

9. Misusing "pay through the post" / informal channels. While Section 71(1) preserves a right to pay by post, modern allocation depends on the correct BP/reference through the SSP or an approved intermediary. A payment without a correct reference can sit unallocated, accruing penalties as though unpaid.

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.

• Section 71 is the master payment provision: tax is due and payable on the prescribed date, paid at the prescribed place, in one sum or instalments (Commissioner's discretion), and unpaid tax attracts Section 71(2) interest from the due date — subject to the special-circumstances interest-free extension (MR Bank 19-HH-779).
• Provisional taxpayers pay QPDs of 10/25/30/35% on 25 Mar / 25 Jun / 25 Sep / 20 Dec (Section 72(7)); a short instalment is deemed unpaid (Section 72(10)) with interest-waiver relief under Section 72(11).
• PAYE is the employer's trust liability, paid on Form P2 by the 10th (Section 73); the monthly-10th family also covers WHT, IMTT, presumptive taxes and royalties (REV 5 series).
• VAT returns and payment are due on the 15th since 1 January 2025 (Section 28(1), Act 7 of 2024) — not the 25th; late VAT carries an automatic 100% penalty plus interest (Section 39), with rates set by the Fifth Schedule (SI 25/2025): policy rate + 5% local, 10% foreign.
• Currency follows the liability (Section 38(4a)): USD-collected tax is paid in USD; mis-currencying risks the Section 38A double-tax penalty and does not discharge the debt; USD and ZiG ledgers do not net.
• You pay the Single Account, not an assessment: money is allocated oldest-debt-first (the administrative cousin of the Section 72(8) set-off) — reconcile the Single Account monthly to avoid the misallocation trap.
• Channels: SSP credit-card / e-banking, or an approved financial intermediary under Finance Act Section 4B, which must credit the CRF within 24 hours (and bears the interest risk if late).
• Pay-now-argue-later (Section 69 / Section 36; Mayor Logistics 14-CC-007): a dispute never stops the interest clock.
• Policy insight: paying correctly is the only reliable way to keep a debt to its principal alone — every secondary charge in the system is a tax on delay or error, and (per Write-Offs and Remission) only those secondary charges are ever remissible.

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Table 1 — Major payment obligations: when, what, where, currency

Tax head	Statutory due date	Form	Channel	Currency rule	Late-payment consequence
PAYE	10th of following month (13th Sched; Section 73)	P2	SSP / intermediary	Currency of remuneration	Section 73(3) interest; non-remittance penalties
Withholding taxes / IMTT / presumptive / royalties	10th of following month	REV 5 / 5A / 5B / 5C	SSP / intermediary	Currency of payment	Section 71(3) interest
Provisional income tax (QPDs)	25 Mar / 25 Jun / 25 Sep / 20 Dec (Section 72(7))	ITF 12B	SSP / intermediary	Currency of income	Section 72(10) deemed unpaid + Section 71(2) interest
Annual income tax balance	30 Apr (31 Dec YOA)	ITF 12C / ITF 1	SSP / intermediary	Currency of income	Section 71(2) interest; set-off Section 72(8)
VAT	15th of following month (Section 28(1), from 1 Jan 2025)	VAT 7	SSP / intermediary	Currency of supply (Section 38(4a))	100% penalty + interest (Section 39); double penalty (Section 38A) if mis-currencied
Capital gains tax	Within 30 days of disposal	CGT 1	SSP / conveyancer WHT	Currency of disposal	interest; withholding by conveyancer/depositary

Table 2 — Interest and penalty rates on late payment (YA 2025)

Tax / default	Penalty	Interest rate	Source	Remission route
Late VAT (local currency)	100% of tax (Section 39(2)(a)(i))	bank policy rate + 5% per month/part-month	5th Sched, SI 273/03 subst SI 25/2025	Section 39(5) (no loss/benefit/intent)
Late VAT (foreign currency)	100% of tax (Section 39(2)(a)(i))	10% per month/part-month	5th Sched, SI 25/2025	Section 39(5)
Mis-currencied VAT (Section 38(4a) breach)	double the tax (primary civil penalty)	—	Section 38A	— (offence on continued default)
Late income tax / QPD	(additional tax separately, Section 46)	Minister's SI rate	Section 71(2)/(3); SI 212/2022	Section 71(2) proviso; Section 72(11)
Late PAYE	non-remittance penalties	Minister's SI rate	Section 73(3); SI 212/2022	Section 73(3) Commissioner direction
Intermediary late remittance	—	15% (USD) / policy+5% (ZWL)	Finance Act Section 4B(4)	— (intermediary's liability)

Table 3 — Worked late-VAT comparison (USD 8,000 net VAT, due 15 Mar 2025)

Paid on	Month-units (from 1 Apr)	Penalty (100%)	Interest (10% p.a. forex)	Total
15 Mar 2025 (on time)	0	0	0	8,000.00
2 Apr 2025	1	8,000.00	66.67	16,066.67
10 Jun 2025	3	8,000.00	200.00	16,200.00
30 Sep 2025	6	8,000.00	400.00	16,400.00

The leap from USD 8,000 to USD 16,066.67 the moment payment slips one day past the deadline shows the dominance of the automatic 100% penalty; interest is comparatively minor but part-month-rounded.

Diagram 1 — The payment decision flow

flowchart TD
 A[Liability created and quantified] --> B{Which tax head?}
 B -->|PAYE / WHT / IMTT| C[Pay by 10th of following month]
 B -->|Provisional income tax| D[Pay QPD 10/25/30/35 on 25Mar/25Jun/25Sep/20Dec]
 B -->|VAT| E[Pay by 15th of following month - Section 28 from 2025]
 B -->|CGT| F[Pay within 30 days of disposal]
 C --> G{Correct currency? Section 38 4a / income currency}
 D --> G
 E --> G
 F --> G
 G -->|No| H[Wrong currency: Section 38A double penalty + debt NOT discharged]
 G -->|Yes| I{Paid on time into Single Account?}
 I -->|No| J[Interest Section 71 2 / Section 39; VAT adds 100% penalty]
 I -->|Yes| K{Allocated to intended head?}
 K -->|No - swept to older debt| L[Misallocation: reconcile + request re-allocation]
 K -->|Yes| M[Liability discharged - debt extinguished]

Diagram 2 — How a payment is allocated (Single Account)

flowchart TD
 P[Payment received into Single Account] --> Q{USD or ZiG column?}
 Q -->|USD| R[USD ledger only - no netting with ZiG]
 Q -->|ZiG| S[ZiG ledger only - no netting with USD]
 R --> T{Oldest debt within tax type?}
 S --> T
 T -->|Older arrear exists| U[Apply to oldest first - Section 72 8 set-off logic]
 T -->|No older debt| V[Apply to intended current liability]
 U --> W[Intended head may remain unpaid - penalty accrues]
 V --> X[Liability settled]
 W --> Y[Reconcile Summary Report - lodge re-allocation in Case Management]

Statutes & sections

• Income Tax Act [Chapter 23:06] — Section 69 (pay-now-argue-later); Section 71 (day, place, manner of payment; instalments; Section 71(2) interest + special-circumstances proviso; Section 71(3) schedule-tax interest); Section 72 (provisional tax; Section 72(7) QPDs 10/25/30/35 on 25 Mar/25 Jun/25 Sep/20 Dec; Section 72(8) set-off allocation; Section 72(10) deficit deemed unpaid; Section 72(11) interest waiver; Section 72(13)–(14) thresholds and SME monthly election); Section 73 (PAYE payment + interest, 13th Sched, P2 by the 10th); Section 74 (persons by whom tax payable); Section 76 (de minimis — no tax under US$0.50 / US$250 final-tax threshold); Section 77(1) (tax deemed a debt due to the State, payable in the prescribed manner and place).
• VAT Act [Chapter 23:12] — Section 27 (tax periods, Categories A–D); Section 28 (returns and payments; 15th-day deadline from 1 Jan 2025, Act 7 of 2024; Section 28(2) nil returns); Section 36 (pay-now-argue-later); Section 38 (manner of payment; Section 38(2)–(3) deposit/provisional payment; Section 38(4)/(4a) currency-of-payment; Section 38(8) USD equivalent); Section 38A (double-tax primary civil penalty for Section 38(4a) breach); Section 39 (penalty 100% + interest for late payment; Section 39(5) remission triad).
• VAT (General) Regulations, SI 273/03 — Fifth Schedule (rates of interest), substituted by SI 25/2025 (19 March 2025): local-currency interest = policy rate + 5%; foreign-currency interest = 10%.
• Finance Act [Chapter 23:04] — Section 4B (payment through approved financial intermediaries; 24-hour CRF credit from 1 Jan 2025; intermediary interest 15% USD / policy+5% ZWL).
• Income Tax (Rate of Interest) Notice, SI 212 of 2022 — interest rate for income-tax purposes under Section 71(2)/(3) .

Case law

• Mayor Logistics (Pvt) Ltd v ZIMRA 14-CC-007 — pay-now-argue-later; constitutional validity of Section 71 payment machinery.
• MR Bank Ltd v ZIMRA 19-HH-779 — Section 71(2) special-circumstances proviso; deliberate misapplication ≠ special circumstance.
• Man Ltd v ZIMRA 20-HH-078 — Section 71(2) interest on unpaid income tax.
• Redan Petroleum (Pvt) Ltd v ZIMRA 23-HH-637 — provisional tax paid in-year, not at year-end.
• SZ (Pvt) Ltd v ZIMRA 20-HH-142 — Section 72(11) interest waiver for QPD shortfall.
• ZIMRA v Packers International (Pvt) Ltd 16-SC-028 — nil return still required (Section 28(2)).
• Delta Beverages (Pvt) Ltd v ZIMRA 23-HH-577; Inamo Investments (Pvt) Ltd v ZIMRA 22-HH-672 / 23-SC-096; Prosperous Days Investments v ZIMRA 21-HH-024 — currency-of-payment under Section 38(4)/(4a).
• VSL (Pvt) Ltd & 3 ors v ZIMRA 19-HH-023; V v ZIMRA 19-HH-643; E.J (Pvt) Ltd v ZIMRA 19-HH-528; R (Pvt) Ltd v ZIMRA 19-HH-792; G (Pvt) Ltd v ZIMRA 22-HH-011 — Section 39(5) remission of VAT penalty/interest.

ZIMRA guidance

• Zimbabwe Tax Compliance Calendar — due-date matrix (note the live conflict: shows VAT at the 25th and QPDs as 10/25/55/90 cumulative; legislation prevails).
• Comprehensive Guide to the ZIMRA Self-Service Portal (TaRMS) — Payments module (credit card / e-banking), Single Account concept (oldest-debt-first allocation; USD/ZiG segregation), Debt Management module (instalment plans).
• Comprehensive Guide to the ITF 12B / VAT 7 / P2 / REV 5 form guides — practical return-and-payment mechanics for each head (cross-referenced).

Continuity: this lesson is the management/payment-stage companion to Introduction to Tax Debt Management (lifecycle), and builds on Creation of Tax Debt (when liability arises), Tax Assessments and Their Role (quantification), Identification and Classification of Tax Debt (four-component anatomy) and Taxpayer Account Management (the Single Account ledger). It feeds forward into Calculation of Interest on Tax Debt, Payment Plans and Instalments, Tax Debt Enforcement Powers and Write-Offs and Remission of Tax Debt (only the secondary charges built up by late payment are ever remissible).