Itcfoundations

Income tax is the single largest direct tax in Zimbabwe and the conceptual foundation on which every other lesson in this chapter is built. It is imposed by Section 6 of the Income Tax Act [Chapter 23:06], the charging section, which directs that "there shall be charged, levied and collected throughout Zimbabwe for the benefit of the Consolidated Revenue Fund an income tax in respect of the taxable income … received by or accrued to or in favour of any person during the year of assessment." Four load-bearing ideas sit inside that one sentence — a charge (the legal power to tax), a base (taxable income), a subject (any person), and a period (the year of assessment) — and this lesson unpacks each from first principles.

The Income Tax Act does not, by itself, tell you how much tax to pay. Under Section 7, the tax "shall … be calculated in accordance with the charging Act" by reference to three things: (a) the taxpayer's taxable income for the year, (b) the appropriate rates of income tax fixed by the charging Act for that year, and (c) the credits to which the person is entitled. The "charging Act" is defined in Section 2 as "the enactment by which credits and rates of tax are fixed" — in practice the Finance Act [Chapter 23:04], re-enacted (and amended) every year through the national Budget. This two-statute design — a permanent Income Tax Act that defines the structure, and an annual Finance Act that sets the numbers — is the most important structural fact in Zimbabwean income tax, and the reason a rate or threshold is always year-specific.

The base is built by a funnel that this chapter calls the gross-income-to-taxable-income funnel, all defined in Section 8(1): gross income (total amounts received/accrued/deemed, from a source within or deemed within Zimbabwe, excluding capital) minus exemptions = "income"; income minus deductions = "taxable income". Only taxable income is charged under Section 6. Zimbabwe taxes on a source basis, not a residence basis — the gateway question is where the income arose, not where the taxpayer lives — a point established in the lessons on Persons Liable (itcliablepersons) and Residence & Source (itcresidence) and assumed throughout.

The year of assessment is defined in Section 2 as "the period of 12 months beginning on the 1st January." This has been the rule since Act 17 of 1997; before 1 April 1997 the tax year ran 1 April to 31 March, and the Act preserves several transitional "broken" years (the 9-month 1997 period; the split 2004 year). Always state the year of assessment a figure belongs to.

For the 2025 year of assessment, employment income of individuals taxed in United States dollars is charged on a progressive scale running from a tax-free threshold of US$1,200 per year (US$100/month) up to a top marginal rate of 40% on annual taxable income exceeding US$36,000, with intermediate bands at 20%, 25%, 30% and 35%. An AIDS Levy of 3% is then charged on the income tax payable by individuals (confirmed on the 2025 ZIMRA foreign-currency tax tables). Companies and trusts are charged at a flat 25% for 2025 (Finance Act; see itccorporate). Tax is administered by the Zimbabwe Revenue Authority (ZIMRA), established under the Revenue Authority Act [Chapter 23:11], acting through the Commissioner and the Commissioner-General (Section 2 definition of "Commissioner"), and all taxpayer information is protected by the preservation-of-secrecy duty in Section 5.

This lesson establishes the vocabulary, the charging mechanism, the two-statute architecture, the year of assessment, the taxable-income funnel, the source principle, and the institutional setting (ZIMRA, self-assessment, currencies). Every later lesson — gross income, exemptions, deductions, capital allowances, PAYE, corporate tax, CGT, VAT — plugs into this frame. Master it and the rest of the chapter becomes the filling-in of detail rather than the learning of something new.

What "income tax" actually is

A tax is a compulsory contribution levied by the State on persons or transactions, for which the payer receives no direct, proportionate return — it funds Government generally rather than buying a specific service. Income tax is a tax whose base is income: the flow of economic gains a person earns over a period. It is a direct tax, meaning it is imposed on, and borne by, the person whose income is taxed (contrast an indirect tax such as Value Added Tax, which is imposed on transactions and ultimately borne by the final consumer — see the VAT lessons). Because income tax is direct, the law must define very carefully whose income, what counts as income, and when it is earned. Those three definitional problems — subject, base, and period — generate almost the entire Income Tax Act.

Income tax in Zimbabwe is also a revenue tax of general application: under Section 6 it is collected "for the benefit of the Consolidated Revenue Fund." The Consolidated Revenue Fund is the central pool, established under the Constitution, into which State revenues are paid and out of which appropriations are made by Parliament. Income tax is therefore not earmarked for a particular purpose; it funds the State at large. (Some levies imposed through the income tax machinery — the AIDS Levy, IMTT, carbon tax — behave differently and are dealt with in itclevies.)

Why income tax sits at the centre of the chapter

Every other topic in this course is a specialisation of, or an exception to, the income tax charge:

• Gross income, exemptions, and deductions answer the question what is the base? — they build the taxable income that Section 6 charges.
• Residence and source answer which receipts are within the charge? — the geographic gateway.
• Capital allowances, farming, mining, partnerships, trusts are special regimes for computing particular taxpayers' taxable income.
• PAYE, provisional tax (QPDs), withholding taxes are collection mechanisms that bring the tax in before or instead of a final assessment.
• Returns, assessments, objections, appeals, recovery, penalties are the administrative spine (see itcretkeep and itcadministration).

If you do not understand the charging mechanism and the funnel, none of those topics will cohere. That is why this lesson teaches them slowly and assumes nothing.

Why it is heavily examined and audited

Income tax foundations are examined because they are transferable: a candidate who can state the charging section, explain the role of the Finance Act, define the year of assessment, and walk the gross-to-taxable funnel can reason about any unfamiliar provision. ZIMRA audit interest is high at exactly the points where the funnel narrows — whether a receipt is gross income at all (capital vs revenue), whether an exemption truly applies, and whether a deduction is genuinely allowable — because each is a place where the base can be understated. The foundational definitions are the vocabulary in which all of those disputes are argued.

B.1 The Income Tax Act [Chapter 23:06] — the permanent structural statute

The Income Tax Act is the principal Act. Its long amendment history (Acts from 5/1967 through to 1/24, 2/24 and 7/2024, as consolidated to 27 May 2025) tells you that the structure endures while the detail is continually amended. For foundations, the indispensable provisions are in Part I (Preliminary), Part II (Administration) and Part III (Income Tax).

Section 6 — Levy of income tax (the charging section)

Section 6: "There shall be charged, levied and collected throughout Zimbabwe for the benefit of the Consolidated Revenue Fund an income tax in respect of the taxable income, as defined in this Part, received by or accrued to or in favour of any person during the year of assessment ending the 31st March, 1968, and each succeeding year of assessment thereafter."

Read it word by word, because every phrase does work:

• "charged, levied and collected" — three verbs marking the three stages of taxation: the charge (the liability arises by law), the levy (the liability is quantified by assessment), and collection (the money is gathered). Section 6 is the source of the legal power; without it, no income tax could lawfully be demanded (a principle the courts guard jealously — taxation requires clear statutory authority).
• "throughout Zimbabwe" — the territorial reach of the charge.
• "for the benefit of the Consolidated Revenue Fund" — the destination, confirming it is a general revenue tax.
• "an income tax in respect of the taxable income, as defined in this Part" — crucially, the charge bites on taxable income, not gross income and not turnover. An assessment raised on gross income rather than taxable income is invalid — see Paperhole Investments (Pvt) Ltd v ZIMRA & 2 Ors (24-HH-149), annotated in the source Act against the definition of "assessment."
• "received by or accrued to or in favour of any person" — the base must have been received or accrued; the subject is any person (defined widely in Section 2).
• "during the year of assessment … and each succeeding year" — the tax is annual and periodic; each year stands on its own.

The source Act annotates Section 6 with Zimplats v ZIMRA (22-HH-845).

Section 7 — Calculation of income tax

Section 6 imposes the charge; Section 7 tells you how to quantify it:

Section 7(1): "The income tax with which a person is chargeable shall, subject to section fifty, be calculated in accordance with the charging Act by reference to — (a) the taxable income of the person in the year of assessment; and (b) the appropriate rates of income tax fixed by the charging Act relating to that year; and (c) the credits to which the person is entitled in terms of the charging Act relating to that year."

Three components, each pointing outward to the charging Act for its numbers:

1. The taxable income — built inside the Income Tax Act by the Section 8 funnel (below).
2. The rates — not in the Income Tax Act; they are "fixed by the charging Act," i.e. the Finance Act, for "that year." This is why rates are always year-specific.
3. The credits — amounts subtracted from the tax itself (not from income), again fixed by the charging Act (e.g. the elderly, blind, disabled and medical credits for individuals; see itctaxindividuals / itccalculation).

Section 7(2) (inserted by Act 12/2006 with effect from 1 January 2007) extends the same calculation to self-assessment returns under Section 37A, where the taxpayer computes its own liability (see itcretkeep). The source Act annotates Section 7 with Gonese I v Minister of Finance and Economic Development (22-HH-265) — a reminder that the rate-fixing function belongs to Parliament through the charging Act, not to a Minister by notice (a theme developed in itclevies).

Section 8 — the gross-income-to-taxable-income funnel

Section 8(1) defines the building blocks of the base. The full anatomy of "gross income" is taught in itcgrossincome; for foundations you must hold the funnel in your head:

• "gross income" — "the total amount received by or accrued to or in favour of a person or deemed to have been received … in any year of assessment from a source within or deemed to be within Zimbabwe excluding any amount … proved by the taxpayer to be of a capital nature," plus the specific inclusions in paragraphs (a)–(t).
• "income" — "the amount remaining of the gross income … after deducting therefrom any amounts exempt from income tax under this Act" (Section 8(1)).
• "taxable income" — "the amount remaining after deducting from the income of any person all the amounts allowed to be deducted from income under this Act" (Section 8(1)).

So the statutory order is fixed and one-directional:

Gross income − Exemptions = Income; Income − Deductions = Taxable income; Taxable income × Rate − Credits = Tax; Tax + AIDS Levy = Total payable.

This funnel is the skeleton of every income tax computation in the chapter. The source Act annotates the gross-income definition with Delta Beverages (Pvt) Ltd v ZIMRA (22-SC-003) and others.

B.2 The Finance Act [Chapter 23:04] — the annual charging Act

The "charging Act" is defined in Section 2 of the Income Tax Act as "the enactment by which credits and rates of tax are fixed." That enactment is the Finance Act [Chapter 23:04], which the source describes (in its own currency-conversion provision) as "this Act … the Charging Act." Its Chapter I is headed "INCOME TAX & OTHER TAXES LEVIED IN TERMS OF THE INCOME TAX ACT," and within it:

• Part I (Preliminary) — interpretation (Section 4), payment of certain taxes in foreign currency (Section 4A), and prompt remittance of revenues through financial intermediaries (Section 4B).
• Part II (Credits to be deducted from income tax) — Section 5, "Credits to which Section 7 of the Taxes Act relates," ties the Finance Act's credits to Section 7(c) of the Income Tax Act. Section 5 also contains the rule that companies and trusts may not deduct most personal credits (only the youth-employment credit Section 13A and the credit for employing physically challenged persons Section 13B), and that where tax is payable in foreign currency the credits (expressed in Zimbabwean currency) are converted using the 22 February 2019 1:1 baseline divided by 10.
• Part III and the Schedule to Chapter I ("Credits and Rates of Income Tax") — fix the actual rates for the year.

The practical consequence: you must read both statutes together for any computation. The Income Tax Act tells you what taxable income is and that it is charged; the Finance Act tells you at what rate and with what credits for the specific year. A figure quoted without its year is meaningless.

Old vs new: why the two-statute split matters for dating

Because the rate-setting Finance Act is re-enacted yearly, Zimbabwean income tax is full of effective-date problems. The Act consolidates dozens of amendments, each with its own commencement (for example, self-assessment under Section 37A took effect 1 January 2007; the prepayment rule in Section 8(3) was inserted by the Finance Act 1 of 2018 with effect from 1 January 2018). The discipline this imposes — which version of the law applied in the year in question? — is a defining feature of accurate tax work and is revisited in every lesson.

B.3 Part II — Administration: ZIMRA, the Commissioner, and secrecy

• Section 3 preserves the Commissioner's powers and delegations; Section 4 has been repealed by the Revenue Authority Act — because administration of the tax was transferred to the Zimbabwe Revenue Authority when it was created under the Revenue Authority Act [Chapter 23:11].
• "Commissioner" is defined in Section 2 (subject to Section 3) as either "the Commissioner in charge of the department of the Zimbabwe Revenue Authority which is declared in terms of the Revenue Authority Act [Chapter 23:11] to be responsible for assessing, collecting and enforcing" the taxes under the Act, or "the Commissioner-General of the Zimbabwe Revenue Authority" in relation to functions delegated to him under that Act. ZIMRA is therefore the administering institution; the Commissioner(-General) is the statutory official who exercises the Act's powers.
• Section 5 — Preservation of secrecy. All persons employed in carrying out the Act must "keep secret, and aid in keeping secret, all information" coming to their knowledge, and may not communicate it except to the taxpayer, the taxpayer's lawful representative, or as required by law or court order (with limited statutory gateways, including amendments made by the Money Laundering and Proceeds of Crime legislation). Taxpayer confidentiality is thus a statutory duty, not merely administrative courtesy — important context for the disclosure obligations in itcretkeep.

B.4 The key Section 2 definitions every foundation rests on

These ten definitions recur in every subsequent lesson; learn them as a set.

C.1 The four elements of any tax charge

Every workable tax answers four questions. Locate each inside Section 6:

1. Is there a charge? (the power) — Yes: "there shall be charged, levied and collected … an income tax." Without an express charge, ZIMRA cannot demand tax; the charge cannot be implied.
2. On whom? (the subject) — "any person," widely defined in Section 2 to include companies, estates, certain trusts, and authorities, but pointedly excluding partnerships (a partnership is transparent: its partners are taxed on their shares, not the firm — see itcliablepersons and itcpartnerships).
3. On what? (the base) — "the taxable income, as defined in this Part." Not gross receipts, not profit in the accounting sense, but taxable income as the Act constructs it.
4. For what period? (the time) — "during the year of assessment." Income tax is an annual periodic tax; each year is a fresh charge.

A fifth, implicit question — at what rate, and against what credits? — is answered not in Section 6 but in Section 7 by reference to the charging Act.

C.2 The source principle (Zimbabwe taxes where income arises)

Zimbabwe operates a source-based income tax. The gross-income definition charges amounts "from a source within or deemed to be within Zimbabwe." The gateway is therefore geographic origin of the income, not the residence of the recipient. A non-resident with a Zimbabwean source is within the charge; a resident's genuinely foreign-source income is generally outside it (subject to the deeming provisions in Sections 10, 12 and 12A, and to special regimes). This is the opposite emphasis from residence-based systems and is developed fully in itcresidence and itcliablepersons; for foundations, simply fix the rule: source first, residence second. "Source" and the deemed-source rules are where a great deal of cross-border tax planning and dispute occurs.

C.3 The gross-income-to-taxable-income funnel, step by step

Take the funnel slowly, because it governs every computation:

Step 1 — Identify gross income (Section 8(1)). Sum every amount received by, accrued to, or deemed to accrue to the person in the year, from a source within or deemed within Zimbabwe, excluding amounts proved by the taxpayer to be of a capital nature — but including the specific paragraphs (a)–(t) even where they might otherwise look capital (the "specific inclusions," itcspecificinclusions). The capital/revenue boundary is itself a major topic (itccapitalvsrevenue); the burden to prove a receipt capital lies on the taxpayer (Section 63).

Step 2 — Subtract exemptions to get "income" (Section 8(1) + Section 14 / Third Schedule). Remove amounts the Act exempts (e.g. certain pensions, scholarships, specified institutions — itcexemptincome). What remains is "income."

Step 3 — Subtract deductions to get "taxable income" (Section 8(1) + Section 15 / Section 16). Deduct every amount the Act allows (the general deduction in Section 15(2) and the specific deductions, capital allowances, etc.), but make no deduction for amounts prohibited by Section 16 (domestic, capital, non-trade expenditure — itcprohibited). What remains is "taxable income."

Step 4 — Apply the rate (Finance Act) to get the tax. Apply the appropriate rate fixed by the charging Act for that year (Section 7(1)(b)). For individuals' employment income this is the progressive scale; for companies and trusts it is the flat corporate rate (25% for 2025 — itccorporate).

Step 5 — Deduct credits (Finance Act) to get tax payable (Section 7(1)(c)). Subtract the credits the charging Act allows for the year (personal credits for individuals; restricted for companies/trusts under FA Section 5(3)).

Step 6 — Add the AIDS Levy. For individuals, add the AIDS Levy of 3% of the income tax payable (confirmed on the 2025 foreign-currency tax tables; the broader levy architecture is in itclevies).

Only the figure that emerges from Steps 1–3 — taxable income — is what Section 6 actually charges. Steps 4–6 convert it into money.

C.4 The year of assessment, transitional years, and "periods within a year"

The year of assessment is "the period of 12 months beginning on the 1st January" (Section 2, substituted by Act 17 of 1997), "and includes any period within such a year of assessment." The italicised phrase matters: a business that starts or ceases mid-year, a person who dies, or a company being wound up may have a year of assessment shorter than 12 months, and the Act's machinery (and the Finance Act's pro-rating of certain credits — FA Section 5(1)(b)) accommodates that.

The definition preserves Zimbabwe's history of broken years, each "deemed for all purposes of this Act to be a year of assessment":

• Before 1 April 1997: the year ran 1 April to 31 March (hence Section 6's reference to the year "ending the 31st March, 1968").
• 1 April – 31 December 1997: a 9-month transitional year, when the system moved to the calendar year.
• 2004: split into an 8-month period (1 Jan – 31 Aug) and a 4-month period (1 Sep – 31 Dec).
• 2005: a further split for the employment income of non-company, non-trust, non-pension-fund taxpayers.

You will rarely compute a pre-1997 year, but the lesson is conceptual: a "year of assessment" is whatever the Act defines it to be for the year in question, and may not be twelve calendar months. Always anchor a computation to the correct year.

C.5 The two currencies: USD and ZiG

Since the multi-currency reforms, Zimbabwean income tax is administered in two currencies in parallel. The Finance Act Section 4A provides for payment of certain taxes in foreign currency, and ZIMRA publishes separate tax tables — the USD (foreign currency) tax tables and the ZiG tax tables — for each year. Where a person earns partly in foreign currency, the law requires the foreign-currency portion to be returned and taxed separately (the USD return, with conversion rules; see itcretkeep on Section 37AA). The Section 8(2) rule resolves exchange-rate differences between accrual and receipt across years. The editor's caveat in the source Act flags the contested status and timing of the ZiG as lawful currency (from 5 April 2024 / 28 October 2024) — a reminder to treat currency questions as period-specific and to use the table for the right year and currency.

C.6 Self-assessment and the modern administrative model

Historically the Commissioner assessed every taxpayer. Since Section 37A (inserted by Act 12/2006, effective 1 January 2007) the dominant model for companies and other "specified taxpayers" is self-assessment: the taxpayer files a return (e.g. the ITF 12C), computes its own tax under Section 7(2), and pays — and that self-assessment is treated as an assessment served on it (see itcretkeep and itccorporate). Employees are taxed largely through PAYE withheld at source under the Thirteenth Schedule. The "Commissioner-assesses" model survives for cases the Act reserves (estimated assessments under Section 45, additional assessments under Section 47). Foundations should register that most income tax is now self-declared and paid up front or withheld, with the Commissioner auditing and adjusting after the fact.

The grounding rules require worked numbers. The following apply the 2025 USD annual tax table (individuals) and the 25% company rate (2025), and add the 3% AIDS Levy where applicable. All figures are illustrative but use the real 2025 USD bands.

The 2025 USD annual individual tax table (employment income):

The "subtract" column is the cumulative adjustment that makes the marginal scale work in a single multiplication: tax = (income × band rate) − subtract.

D.1 Individual employee (Tariro, a Harare accountant)

Tariro earns a salary of US$30,000 for 2025 with no other income and (for simplicity) no credits. Her income is employment income, so the progressive scale applies, and her US$30,000 falls in the 35% band (24,001 – 36,000).

Taxable income USD 30,000
Tax = (30,000 × 35%) − 2,220
 = 10,500 − 2,220 USD 8,280
AIDS Levy (3% × 8,280) USD 248.40
Total income tax payable USD 8,528.40

Her average (effective) rate is 8,528.40 ÷ 30,000 ≈ 28.4%, well below her marginal rate of 35% — because the first US$1,200 is tax-free and each lower band is taxed at its lower rate. This gap between marginal and average rate is the defining feature of a progressive tax and a constant source of confusion among employees.

D.2 Sole trader (Brian, a self-employed electrician — an SME individual)

Brian runs an unincorporated electrical business. He is an individual, but his profit is business (trade) income, not employment income. Suppose for 2025: gross receipts US$48,000; exempt amounts nil; allowable deductions (materials, transport, tools, allowances) US$20,000; no prohibited items.

Gross income (trade) USD 48,000
Less: exemptions USD 0
= Income USD 48,000
Less: allowable deductions (Section 15) USD 20,000
= Taxable income USD 28,000 (falls in 35% band)
Tax = (28,000 × 35%) − 2,220
 = 9,800 − 2,220 USD 7,580
AIDS Levy (3% × 7,580) USD 227.40
Total income tax payable USD 7,807.40

Two foundational points are visible. First, the funnel is identical whether income is salary or trade profit — gross income, then exemptions, then deductions, then rate, then credits, then levy. Second, because Brian is an individual, the progressive scale (not the company rate) applies to his trade profit; incorporation would switch him to the flat company rate, which is the planning question explored in itctaxindividuals and itccorporate. As a sole trader he pays by provisional tax (QPDs) during the year and reconciles on assessment.

D.3 SME company (Kushinga Hardware (Pvt) Ltd)

Kushinga Hardware is a small registered company. A company is a separate "person" (Section 2: "any association wheresoever incorporated") taxed in its own right at the flat 25% company rate for 2025 — the progressive individual scale never applies to it, and (under FA Section 5(3)) it gets no personal credits. Suppose 2025 taxable income (after the full funnel) is US$80,000.

Taxable income USD 80,000
Company income tax (25%) USD 20,000
AIDS Levy — see note

Kushinga files an ITF 12C self-assessment and pays in QPD instalments through the year (see itccorporate and itcretkeep). The foundational lesson here is the separate legal personality of the company: its income is its own, taxed at the corporate rate, and only reaches its shareholders as dividends (themselves subject to shareholders' tax — see itccorporate).

D.4 Large corporate / multinational

A large or multinational group encounters the same charging section and the same 25% rate, but its foundational concerns shift to scale and structure: confirming which receipts have a Zimbabwean source or are deemed to (Sections 10, 12, 12A — itcresidence); whether a permanent establishment exists (Section 19B); whether special regimes apply (mining, petroleum, special mining lease); the currency in which different streams are earned (USD vs ZiG returns); transfer pricing and anti-avoidance (Section 98 and the 35th Schedule — itctransferpricing); and Domestic Minimum Top-Up Tax (Section 12B, a recent addition aimed at large multinational groups). The foundations do not change — Section 6 charges taxable income, Section 7 calculates it via the charging Act — but the volume of definitional and source questions multiplies. Compliance also tightens: large corporates are the heart of the self-assessment, QPD and audit machinery.

D.5 Comparing the three groups on one base

If each of the above had US$30,000 of taxable income for 2025:

The point is not that one is "better" — it is that the rate structure attaches to the taxpayer type, and the same base produces different tax. Choosing a vehicle (individual vs company) is therefore a foundational tax-planning decision, taken up in later lessons.

The following authorities are annotated in the source Income Tax Act (as consolidated 27 May 2025) against the foundational provisions. Because the source gives the citation and the proposition rather than the full judgment, the facts and ratios are flagged for verification before being relied on beyond the annotated point.

• Zimplats v ZIMRA (22-HH-845) — annotated against the charging Section (Section 6) and the gross-income definition. Stands, at foundational level, for the operation of the charge on amounts received/accrued from a Zimbabwean source. (Confirm full facts/ratio before citing beyond the annotated proposition.)
• Gonese I v Minister of Finance and Economic Development (22-HH-265) — annotated against Section 7 (calculation by reference to rates "fixed by the charging Act"). Reinforces that the power to fix rates is exercised through the charging Act (a constitutional-law theme about Parliament's taxing power that recurs, with the IMTT and carbon-tax challenges, in itclevies).
• Delta Beverages (Pvt) Ltd v ZIMRA (22-SC-003) — annotated against the gross-income definition (Section 8(1)); foundational authority on what constitutes "income" within the funnel (developed fully in itcgrossincome).
• Paperhole Investments (Pvt) Ltd v ZIMRA & 2 Ors (24-HH-149) — annotated against the definition of "assessment," holding (per the annotation) that an assessment raised on gross income rather than taxable income is invalid — a direct illustration that Section 6 charges taxable income.
• TL v ZIMRA (20-HH-413) and Barclays Bank of Zimbabwe v ZIMRA (04-HH-162) — annotated against "assessment": an assessment must be intelligible (not "lumped-up figures without any explanation") and must notify the taxpayer of the 30-day objection window — foundational due-process points carried into itcadministration and itcobjections.
• Zimbabwe Revenue Authority v FC Platinum (22-SC-044) — annotated against the definition of "company" ("any association wheresoever incorporated"), confirming the breadth of the corporate "person."
• Mota Engenharia Construction SA v ZIMRA (22-SC-115) — annotated against "person," confirming a non-resident entity is a "person" within the charge (the source-not-residence gateway in action).

Where no Zimbabwean authority is on point, foundational principles rest on the statute itself and on long-settled common-law interpretive rules (e.g. that a charge to tax must be clearly imposed and is construed in the taxpayer's favour where genuinely ambiguous). Do not substitute an invented case for the statute.

1. Charging tax on gross income (or turnover) instead of taxable income. Section 6 charges taxable income. Computing tax on receipts, or stopping the funnel before deductions, overstates the liability — and an assessment built that way is invalid (Paperhole Investments 24-HH-149). Always run the full funnel.
2. Quoting a rate or threshold without its year. Rates and bands live in the annual Finance Act and change yearly; the 2025 USD bands are not the 2024 bands and not the ZiG bands. A figure without a stated year of assessment and currency is unusable.
3. Confusing marginal rate with average rate. An employee in the 40% band does not pay 40% of all income — only of the slice above US$36,000. Mislabelling the marginal rate as the effective rate badly overstates tax (see D.1).
4. Treating residence as the gateway. Zimbabwe taxes on source. Assuming a resident's foreign income is automatically taxable, or that a non-resident is automatically outside the charge, inverts the rule (see itcresidence). Source first.
5. Forgetting the AIDS Levy on individuals. Individuals' income tax attracts a 3% AIDS Levy on the tax payable. Omitting it understates the bill (see D.1–D.2 and itclevies).
6. Applying the individual progressive scale to a company (or vice-versa). Companies and trusts are charged at the flat corporate rate (25% for 2025) and get no personal credits (FA Section 5(3)); the progressive scale is for individuals. Mixing them is a classic computation error.
7. Treating a partnership as a taxpayer. A partnership is excluded from the definition of "person" — it is transparent; the partners are taxed on their shares (itcliablepersons, itcpartnerships). Assessing "the partnership" is wrong.
8. Assuming the year of assessment is always 12 calendar months. It "includes any period within" a year; cessation, death, or winding-up can create a shorter year, and historical broken years exist. Anchor the computation to the correct year as defined.
9. Ignoring the two-currency split. Foreign-currency and ZiG income are returned and taxed separately, on separate tables. Lumping them together, or using the wrong currency table, produces the wrong tax (see itcretkeep Section 37AA).
10. Reading the Income Tax Act for the rates. The Income Tax Act has the structure; the rates and credits are in the Finance Act. Looking for the rate inside [Chapter 23:06] is a beginner's dead end — Section 7 expressly sends you to the charging Act.

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 6 is the charge. Income tax is "charged, levied and collected … for the benefit of the Consolidated Revenue Fund" on the taxable income of any person for the year of assessment. Tax is charged on taxable income, never on gross receipts (Paperhole Investments 24-HH-149).
• Section 7 is the calculation, and it points outward to the charging Act: tax = function of taxable income, the rates fixed by the charging Act for that year, and the credits for that year.
• Two statutes, read together. The Income Tax Act [Chapter 23:06] is the permanent structure; the Finance Act [Chapter 23:04] is the annual charging Act that fixes rates and credits. Every rate/threshold is therefore year-specific (and currency-specific).
• The funnel is the skeleton. Gross income − exemptions = income; income − deductions = taxable income; × rate − credits = tax; + AIDS Levy = total payable. Memorise it; every later lesson fills it in.
• Source, not residence, is the gateway (Section 8(1)). A Zimbabwean source brings even a non-resident person within the charge (Mota Engenharia 22-SC-115).
• "Person" is wide but excludes partnerships. Companies ("any association wheresoever incorporated," FC Platinum 22-SC-044), estates and certain trusts are persons; partnerships are transparent.
• Year of assessment = 12 months from 1 January (since Act 17/1997), but "includes any period within" a year — it may be shorter, and historical broken years exist.
• Rates by taxpayer type (2025). Individuals: progressive 0%→40% (tax-free up to US$1,200; top band above US$36,000) plus a 3% AIDS Levy. Companies/trusts: flat 25% with no personal credits (FA Section 5(3)); company AIDS-Levy treatment.
• ZIMRA administers; the Commissioner acts; secrecy binds. The tax is run by the Zimbabwe Revenue Authority under the Revenue Authority Act [Chapter 23:11]; taxpayer information is protected by the Section 5 preservation-of-secrecy duty.
• Self-assessment and two currencies are the modern reality. Most income tax is self-declared (Section 37A, from 2007) or withheld (PAYE), and USD and ZiG income are returned and taxed separately on separate tables.
• Big-picture policy. A source-based, progressive, annually-rated income tax balances revenue, equity (progressivity, the tax-free threshold) and administrability (PAYE, self-assessment, withholding) — the design choices that the rest of this chapter operationalises.

Table 1 — The two-statute architecture: what each Act supplies

Table 2 — The gross-income-to-taxable-income funnel

Table 3 — 2025 USD annual individual tax table (employment income)

Source: ZIMRA PAYE Foreign-Currency Tax Tables, January–December 2025. AIDS Levy = 3% of the individual's tax payable. Companies/trusts: flat 25% (Finance Act; see itccorporate).

Diagram 1 — Is a receipt within the income tax charge, and how is it taxed?

flowchart TD
 A[Amount received or accrued] --> B{From a source within or deemed within Zimbabwe?}
 B -->|No| C[Outside the charge - not gross income]
 B -->|Yes| D{Proved to be of a capital nature?}
 D -->|Yes, and no specific inclusion| E[Excluded; consider CGT]
 D -->|No, or a specific inclusion applies| F[Include in GROSS INCOME - Section 8 1]
 F --> G[Less exemptions = INCOME]
 G --> H[Less deductions = TAXABLE INCOME - charged by Section 6]
 H --> I{Taxpayer type?}
 I -->|Individual| J[Progressive scale 0 to 40 percent + 3 percent AIDS Levy]
 I -->|Company or trust| K[Flat 25 percent, no personal credits]
 J --> L[Tax payable for the year]
 K --> L

Diagram 2 — The two-statute calculation flow (Section 6 → Section 7 → charging Act)

flowchart LR
 A[Income Tax Act Section 6: charge on taxable income] --> B[Income Tax Act Section 7: calculate]
 B --> C{Refer to the charging Act for the year}
 C --> D[Taxable income - built in ITA Section 8]
 C --> E[Rates fixed by Finance Act]
 C --> F[Credits fixed by Finance Act]
 D --> G[Income tax for the year]
 E --> G
 F --> G
 G --> H[Add AIDS Levy for individuals]
 H --> I[Total tax payable - year and currency specific]

Statutes & sections — Income Tax Act [Chapter 23:06] (consolidated to 27 May 2025)

• Section 2 — interpretation: definitions of "charging Act," "Commissioner," "company," "person," "taxpayer," "trade," "assessment," "income," "taxable income," and "year of assessment" (12 months from 1 January; substituted by Act 17/1997).
• Section 3 / Section 4 — administration; Section 4 repealed by the Revenue Authority Act [Chapter 23:11] (transfer of administration to ZIMRA).
• Section 5 — preservation of secrecy (taxpayer confidentiality).
• Section 6 — levy of income tax (the charging section): income tax on taxable income for the Consolidated Revenue Fund (annotated Zimplats v ZIMRA 22-HH-845; Paperhole Investments 24-HH-149 on assessment of taxable vs gross income).
• Section 7 — calculation of income tax "in accordance with the charging Act" by reference to taxable income, rates and credits; Section 7(2) self-assessment (Act 12/2006, w.e.f. 1 Jan 2007) (annotated Gonese I v Minister of Finance 22-HH-265).
• Section 8(1) — definitions of "gross income," "income" and "taxable income" (the funnel); Section 8(2) exchange-rate rule; Section 8(3) prepayments (FA 1/2018) (annotated Delta Beverages 22-SC-003).
• Section 37A — self-assessment (referenced; see itcretkeep).

Finance Act [Chapter 23:04] (the charging Act, consolidated to 27 May 2025)

• Chapter I — "Income Tax & Other Taxes Levied in terms of the Income Tax Act"; Section 4A payment of certain taxes in foreign currency; Section 4B prompt remittance through financial intermediaries.
• Section 5 — credits to which Section 7 of the Taxes Act relates; proportionate credit for periods under 12 months (Section 5(1)(b)); companies/trusts barred from most credits (Section 5(3)); foreign-currency credit conversion (22 Feb 2019 baseline ÷ 10).
• Schedule to Chapter I — Credits and Rates of Income Tax (annual rates; individual progressive scale and company rate).

Rates / ZIMRA guidance relied on

• ZIMRA PAYE Foreign-Currency (USD) Tax Tables, January–December 2025 — annual individual bands 0%/20%/25%/30%/35%/40% (tax-free to US$1,200; top band above US$36,000); AIDS Levy 3% of individuals' tax payable.
• 2025 ZiG Tax Tables — parallel ZiG bands (separate currency).
• Revenue Authority Act [Chapter 23:11] — establishment of ZIMRA; office of the Commissioner-General.

Case law (as annotated in the source Income Tax Act)

• Zimplats v ZIMRA (22-HH-845) — operation of the charge (Section 6) / gross income.
• Gonese I v Minister of Finance and Economic Development (22-HH-265) — rates fixed by the charging Act (Section 7).
• Delta Beverages (Pvt) Ltd v ZIMRA (22-SC-003) — gross-income definition (Section 8(1)).
• Paperhole Investments (Pvt) Ltd v ZIMRA & 2 Ors (24-HH-149) — assessment must be on taxable, not gross, income.
• TL v ZIMRA (20-HH-413); Barclays Bank of Zimbabwe v ZIMRA (04-HH-162) — assessments must be intelligible and notify the 30-day objection right.
• ZIMRA v FC Platinum (22-SC-044) — "company" = any association wheresoever incorporated.
• Mota Engenharia Construction SA v ZIMRA (22-SC-115) — a non-resident entity is a "person" within the charge.

Cross-references (TAXTAMI chapter)

• itcliablepersons — "person," taxpayer, partnership transparency, source-not-residence gateway, representative taxpayers.
• itcgrossincome — full anatomy of Section 8(1); the inclusion paragraphs; capital exclusion.
• itcexemptincome / itcdeductions / itcprohibited — the exemption and deduction stages of the funnel.
• itcresidence — source and deemed-source (Sections 10, 12, 12A), permanent establishment (Section 19B), DTAs.
• itccorporate — company as a separate person; 25% rate; self-assessment (ITF 12C); QPDs (Section 72).
• itclevies — AIDS Levy architecture and other income-based levies; Parliament's rate-fixing power.
• itcretkeep — returns, self-assessment (Sections 37, 37A, 37AA), record-keeping, ITF 263.