Itclevies

Beyond the headline income tax charged on taxable income under Sections 6 and 7 of the Income Tax Act [Chapter 23:06] (as established in the lesson on Persons Liable to Income Tax and Corporate Income Tax), the Zimbabwean fiscal system runs a wide family of levies and special taxes that ride alongside, or sit just outside, the ordinary income-tax computation. Some are calculated on the income tax itself (the AIDS levy), some on the value or volume of a transaction (the intermediated money transfer tax, the automated financial transactions tax), some on the quantity of a commodity (the carbon tax per litre of fuel), and some on the gross value of a receipt or asset (the property/insurance commission tax, the non-executive directors' fees tax, the wealth tax, the lithium and dimensional-stone levy). This lesson maps that whole family, explains why each exists, and walks the governing provisions clause by clause.

The architecture is consistent and worth memorising at the outset. For almost every levy the substantive charging section sits in Part V of the Income Tax Act — Sections 36A to 36Q — each of which says, in nearly identical words, that "there shall be charged, levied and collected … a [named] tax/levy in accordance with the [named] Schedule at the rate fixed from time to time in the charging Act." The mechanics (who collects, who is exempt, what is a taxable transaction) live in the matching numbered Schedule to the Income Tax Act, and the rate is supplied year-by-year by the Finance Act [Chapter 23:04] in its parallel Sections 22A to 22S. So to advise on any one levy you read three things together: the 36-series charging section, its Schedule, and the Finance Act 22-series rate. This three-part structure is the single most important idea in the lesson.

The AIDS levy is the exception that proves the rule, and it must be handled honestly. It is the levy practitioners quote most often — an additional charge calculated as a percentage of the income tax payable, long understood to be 3%, producing the familiar effective company rate of about 25.75% on the 25% corporate rate established in Corporate Income Tax. However, the source Act files read for this lesson (the Income Tax Act and Finance Act as at 27 May 2025) do not contain a discrete "AIDS levy" charging section or rate, so its precise statutory home and current rate are flagged for verification below rather than asserted as confirmed source text. The principle (a surcharge on income tax dedicated to the National AIDS Trust Fund) is described; the specific figure is flagged.

The intermediated money transfer tax (IMTT) — Zimbabwe's famous "2 cents" tax — is charged by Section 36G of the Income Tax Act and detailed in the Thirtieth Schedule, with the rate set by Section 22G of the Finance Act. As at 27 May 2025 the operative rate is US$0.02 (2%) on every dollar (or ZiG, or gold-backed digital token) transacted, with a flat cap of US$10,150 on any single transaction equal to or exceeding US$500,000, and the same 2% on outbound foreign payments. The IMTT carries a long list of exempt transactions in the Thirtieth Schedule (remuneration, tax payments to ZIMRA, marketable securities, intra-corporate treasury transfers, pension and medical-aid flows, wallet-to-bank transfers, and many more), and a turbulent legal history culminating in M. Mlilo v Minister of Finance 19-HH-605, where the High Court declared the Minister'Section 2018 regulations (and hence the affected rate) ultra vires before Parliament re-enacted them.

The carbon tax is charged by Section 36E and the Twenty-Eighth Schedule, with rates in Section 22E of the Finance Act expressed per litre of petroleum product (the operative figures being 74.6 Zimbabwe cents per litre of diesel and 229.4 Zimbabwe cents per litre of petrol on the standard import basis, alongside an older "US$0.04 per litre or 5% of CIF, whichever is greater" formulation), plus a US$10 per vehicle per month charge on visitors driving foreign-registered cars. Like the IMTT, the carbon tax has been litigated — Gonese I v Minister of Finance and Economic Development 22-HH-265 again declared the section illegal on a delegation-of-powers point.

The remaining levies — automated financial transactions tax (Section 36B, US$0.05 per withdrawal, 1% above US$1,000), tobacco levy (Section 36A, 1.5c buyers / 0.75c sellers), demutualisation levy (Section 36D, 2.5%), NOCZIM debt-redemption and strategic-reserve levy (Section 36H), property/insurance commission tax (Section 36I, 20%), tax on non-executive directors' fees (Section 36J, 20%), petroleum importers levy (Section 36K, US$0.05/litre), bookmakers and punters tax (Section 36L, 3% / 10%), wealth tax (Section 36O, 1% over US$250,000, capped US$50,000) and the lithium/black-granite/dimensional-stone levy (Section 36P, 2%) — are each surveyed with their confirmed rate and Schedule. The lesson closes with worked USD computations for individuals, SMEs and corporates, a master comparison table of the whole levy family, and a Mermaid decision tree for classifying any payment against the IMTT. Throughout, the accuracy-over-completeness rule governs: every rate stated is the figure in the 27 May 2025 source Acts, dated to its year of effect, and anything the sources do not confirm (most importantly the AIDS levy) is flagged, not invented.

A modern revenue system never relies on a single tax. Income tax — the charge on a person's taxable income under Section 6 of the Income Tax Act [Chapter 23:06] — is powerful but slow and narrow: it only reaches people and companies that actually make assessable profits, it is collected long after the income arises, and it is easy to under-declare. A government that funded itself on income tax alone would have a thin, volatile and easily-eroded base. So every fiscal system layers on a family of levies and special taxes that catch economic activity from different angles — at the point of spending, at the point of moving money, at the point of consuming a commodity, or at the point of holding an asset. Collectively these broaden the base, smooth the timing of revenue, and let the state pursue policy goals (discouraging pollution, funding a national health response, taxing wealth) that the income tax is poorly shaped to serve.

A levy, in Zimbabwean statutory usage, is simply a compulsory charge imposed by statute for the benefit of the State — in almost every case here, "for the benefit of the Consolidated Revenue Fund." The word "levy" carries no magic; what matters is the base on which it is calculated. That base is the organising idea of this lesson. We can sort the whole family into four types by base:

1. Levies on the income tax itself. The AIDS levy is the archetype — a surcharge expressed as a percentage of the income tax otherwise payable. Its base is therefore the tax, not the income, and it rises and falls automatically with the taxpayer's income-tax bill.
2. Levies on the movement or value of a transaction. The intermediated money transfer tax (IMTT) and the automated financial transactions tax (AFTT) are charged when money moves through the banking or mobile-money system. Their base is the amount transacted or withdrawn, not profit — so they are paid even by a loss-making business.
3. Levies on the quantity or value of a commodity. The carbon tax and the petroleum importers levy are charged per litre of fuel; the tobacco levy is charged on the price of auction and contract tobacco; the lithium and dimensional-stone levy on the gross value of those minerals. These are essentially excise-style charges sitting inside the Income Tax Act's architecture.
4. Levies on the gross value of a particular receipt or asset. The property or insurance commission tax, the tax on non-executive directors' fees, the bookmakers and punters tax, the demutualisation levy and the wealth tax each take a percentage of a defined gross amount — a commission, a fee, gross takings or winnings, a member's interest in a demutualising society, or the rateable value of a dwelling.

Why does this matter to a taxpayer or adviser in Zimbabwe? Because these levies are where the real, day-to-day money is for most businesses. A trading company may pay corporate income tax once a year through its quarterly provisional payments; but it pays IMTT every single time it makes an electronic payment, AFTT on cash withdrawals, and carbon tax embedded in every litre of fuel its fleet burns. For a high-volume, low-margin business the levies can dwarf the income tax. And because the levies are transaction-based, they are paid in cash, up front, regardless of profitability — which is exactly why ZIMRA likes them and why getting their treatment right (especially the IMTT exemptions) is commercially significant.

This is also a high ZIMRA-audit area. The transaction taxes are collected by intermediaries — banks, mobile-money operators, fuel importers, auction floors — who act as agents of the Commissioner-General. An intermediary that under-collects or remits late is personally exposed (see Section 4B of the Finance Act on prompt remittance, discussed in Section C). And because the IMTT exemption list is long and technical, businesses routinely over-pay (failing to claim an available exemption) or under-pay (treating a taxable transfer as exempt) — both of which surface on audit.

Finally, this lesson sits at a crossroads in the chapter. It draws on gross income and the charge to tax (the income-tax base the AIDS levy rides on), connects forward to withholding taxes (several of these levies are collected by withholding at source), and overlaps with VAT (the fast-food and plastic-bag surcharges are actually collected through the VAT Act) and with mining taxation (royalties and the mineral levies). Where another lesson owns a topic in full — presumptive tax, mining royalties, VAT surcharges — this lesson cross-references rather than re-teaches.

B1. The three-part structure

Almost every levy in this lesson is built from three interlocking pieces:

• a charging section in Part V of the Income Tax Act [Chapter 23:06], numbered 36A–36Q, which creates the levy and points to a Schedule and to "the charging Act" for the rate;
• a numbered Schedule to the Income Tax Act, which sets out the machinery — definitions, who is liable, who collects, who is exempt, how and when it is paid; and
• a rate-fixing section in the Finance Act [Chapter 23:04], numbered 22A–22S, which supplies the actual percentage or amount for the year.

The phrase that recurs through Part V is the template: "There shall be charged, levied and collected throughout Zimbabwe for the benefit of the Consolidated Revenue Fund a [named] tax in accordance with the [named] Schedule at the rate fixed from time to time in the charging Act." Read it once and you can read all of them. The "charging Act" is the Finance Act — the constitutional device by which Parliament sets and adjusts rates annually without re-opening the Income Tax Act itself. This separation (the Taxes Act creates the tax; the Finance Act sets the rate) is the same architecture explained in Corporate Income Tax for income tax under Section 7, and it was the subject of Gonese v Minister of Finance 22-HH-265.

The master map of the family, as confirmed in the Income Tax Act (Part V) and the Finance Act (Part III), is:

ITA charging s.	Levy	ITA Schedule	Finance Act rate s.
36A	Tobacco levy	Twenty-Fourth	22A
36B	Automated financial transactions tax (AFTT)	Twenty-Fifth	22B
36C	Presumptive tax	Twenty-Sixth	22C
36D	Demutualisation levy	Twenty-Seventh	22D
36E	Carbon tax	Twenty-Eighth	22E
36G	Intermediated money transfer tax (IMTT)	Thirtieth	22G
36H	NOCZIM debt-redemption levy & strategic reserve levy	Thirty-First	22H
36I	Property or insurance commission tax	Thirty-Second	22I
36J	Tax on non-executive directors' fees	Thirty-Third	22J
36K	Petroleum importers levy	Thirty-First	22L
36L	Bookmakers tax and punters tax	Thirty-Sixth	22M
36O	Wealth tax	(in-section)	22O
36P	Levy on lithium, black granite, quarry & dimensional stone	(in-section)	22P
36Q	Mining royalties	Thirty-Seventh	22Q

(Sections 36F, 36M and 36N are repealed or "not enacted" in the source Act. Section 22K of the Finance Act also charges a legacy 5% tax on the exercise of share options granted before 1 February 2009, a transitional charge with no separate 36-series section.)

B2. The AIDS levy — principle confirmed, specifics flagged

The AIDS levy is the levy most often quoted in practice: a surcharge calculated as a percentage of the income tax chargeable on a taxpayer, dedicated historically to the National AIDS Trust Fund that finances Zimbabwe's HIV/AIDS response. Because its base is the income tax itself, it applies to individuals, companies and trusts alike and is computed after the income tax is determined.

However, the source Act files read for this lesson — the Income Tax Act [Chapter 23:06] and the Finance Act [Chapter 23:04], both as at 27 May 2025 — do not contain a discrete "AIDS levy" charging section or a rate provision for it. A keyword search of both Acts returns no AIDS-levy charging provision. Accordingly:

The teaching point stands regardless of the missing specifics: a levy on the tax (rather than on income, a transaction or a commodity) is automatically proportional to the income-tax bill — a loss-making company with nil income tax pays nil AIDS levy, while a highly profitable company pays the levy on its whole income-tax charge. This is structurally different from every transaction levy in this lesson, which is paid irrespective of profit. The dedicated treatment of the AIDS levy's mechanics belongs with whichever lesson the syllabus assigns it; here we anchor the concept and flag the figure.

B3. The intermediated money transfer tax — Section 36G and the Thirtieth Schedule

Section 36G of the Income Tax Act (inserted by Act 15/2002 w.e.f. 1 January 2003; substituted by Act 13/2023 w.e.f. 1 January 2024) charges the IMTT. Clause by clause:

• Section 36G(1) defines the "Zimbabwe gold-backed digital token" as "a digital investment asset issued by the Reserve Bank of Zimbabwe … one unit of which represents one milligram of gold of 99% purity." This brings ZiG-token transfers into the IMTT net.
• Section 36G(2) is the operative charge: "There shall be charged, levied and collected throughout Zimbabwe for the benefit of the Consolidated Revenue Fund an intermediated money transfer tax in accordance with the Thirtieth Schedule at the rate fixed from time to time in the charging Act."
• Section 36G(3) permits a different rate to be fixed for transfers of Zimbabwe gold-backed digital tokens.

The Thirtieth Schedule supplies the machinery: who is a financial institution (banks, building societies, the RBZ, POSB, IDBZ, the postal company, mobile-banking and mobile-money platform operators, registered money-transfer services), what is a "transaction on which the tax is payable", and — critically — the long list of transactions the definition "does not include" (the exemptions in Section C below).

The rate is in Section 22G of the Finance Act, which has been substituted repeatedly (FA(No.2) 10/2022; SI 88/2023; Act 13/2023; the Finance Act 2024 w.e.f. 3 May 2024). The operative rate as at 27 May 2025 is US$0.02 (i.e. 2%) on every United States dollar — and on every ZiG, and on every gold-backed digital token — or part thereof, for each transaction on which the tax is payable, with a flat cap of US$10,150 where a single taxable transaction equals or exceeds US$500,000, and the same US$0.02 per dollar on every outbound foreign payment.

B4. The carbon tax — Section 36E and the Twenty-Eighth Schedule

Section 36E (inserted by Act 18/2000 from 1 January 2001) charges a carbon tax "in accordance with the Twenty-Eighth Schedule at the rate fixed from time to time in the charging Act." The rate is in Section 22E of the Finance Act. The provision has a tangled amendment history and was declared illegal in Gonese I v Minister of Finance 22-HH-265 (a delegation-of-powers challenge). The operative rate structure as at 27 May 2025 is:

• a base formulation of ZWL$2.29 or US$0.04 per litre of petroleum product, or 5% of the cost-insurance-freight (CIF) value, whichever is greater, on imports by the State oil procurement entity or a licensed bulk importer (Section 22E(1));
• updated per-litre figures of 32.5 Zimbabwe cents per litre of diesel and 100 Zimbabwe cents per litre of petrol (Section 22E(1a)), and 74.6 Zimbabwe cents per litre of diesel and 229.4 Zimbabwe cents per litre of petrol (Section 22E(1b)) on the cost-insurance-freight value of product imported otherwise than with "free funds"; and
• a visitor's carbon tax of US$10 per vehicle for each month (or part-month) that a visitor drives a foreign-registered motor vehicle in Zimbabwe (Section 22E(2)).

B5. The other levies — confirmed charging sections and rates

The remaining members of the family, each confirmed in the source Acts:

• Tobacco levy (Section 36A; Twenty-Fourth Schedule; FA Section 22A): 1.50 cents per dollar on buyers of auction and contract tobacco; 0.75 cents per dollar on sellers, of the price withheld at the auction floor.
• Automated financial transactions tax (Section 36B; Twenty-Fifth Schedule; FA Section 22B): on bank withdrawals — a local-currency equivalent of US$0.05 for each withdrawal above US$100 (and US$0.05 for each withdrawal of US$1,000 or less), and 1% of the value for each withdrawal above US$1,000.
• Demutualisation levy (Section 36D; Twenty-Seventh Schedule; FA Section 22D): 2.5% of the amount, computed per Zimbabwean member of the demutualising mutual society.
• NOCZIM debt-redemption levy and strategic reserve levy (Section 36H; Thirty-First Schedule; FA Section 22H): the strategic reserve levy is 0.187 US cents per litre of diesel and 0.247 US cents per litre of petrol (substituted by SI 50/2025 w.e.f. 9 May 2025); the NOCZIM debt-redemption levy lapses once the NOCZIM Sinking Fund debts are repaid (Section 36H(2)).
• Property or insurance commission tax (Section 36I; Thirty-Second Schedule; FA Section 22I): 20% of each dollar of commission paid to estate agents and insurers.
• Tax on non-executive directors' fees (Section 36J; Thirty-Third Schedule; FA Section 22J): 20% of each dollar of the fees.
• Petroleum importers levy (Section 36K; Thirty-First Schedule; FA Section 22L): US$0.05 per litre of petroleum product transported by road by a petroleum importer.
• Bookmakers tax and punters tax (Section 36L; Thirty-Sixth Schedule; FA Section 22M; substituted by FA(No.2) 7/2024 w.e.f. 1 January 2025): 3% of each dollar of a bookmaker's gross monthly takings, and 10% of each dollar of a punter's gross winnings (collected by the bookmaker).
• Tax on exercise of pre-1 February 2009 share options (FA Section 22K): 5% of each US dollar of the market value of the shares on the date the option is exercised — a transitional charge overriding paragraph (t) of the gross-income definition in Section 8(1).
• Wealth tax (Section 36O; FA Section 22O; inserted by Act 13/2023 w.e.f. 1 January 2024): 1% of the value of a dwelling other than a principal private residence where that value exceeds US$250,000, with a maximum liability of US$50,000 per annum per taxable dwelling. Collected (for now) by local authorities alongside rates. Subject to constitutional challenge in Matewu C v Minister of Finance, Parliament & AG 24-HH-590.
• Levy on lithium, black granite, quarry stones and dimensional stone (Section 36P; FA Section 22P; inserted by Act 13/2023, substituted by FA(No.2) 7/2024 w.e.f. 1 January 2025): 2% of the gross value of the sale within Zimbabwe or on export, payable in the currency of trade.
• Mining royalties (Section 36Q; Thirty-Seventh Schedule; FA Section 22Q): charged per Chapter VII — covered in Taxation of Mining Operations.
• Fast-food surcharge (FA Section 22R) and disposable-plastic-bag surcharge (FA Section 22S): charged through the VAT Act (Sections 12F and 12G respectively) — 1% on the sale value of specified fast foods, and 20% on the sale or CIF value of disposable plastic carrier bags. Mechanically these are VAT-collected surcharges rather than Income Tax Act levies, and are noted here only for completeness; VAT lessons own them.

B6. Collection machinery — Section 4B of the Finance Act

A cross-cutting provision governs how all these revenues move. Section 4B of the Finance Act (inserted by FA(No.2) 10/2022) provides that where the Commissioner-General has an account with an "approved financial intermediary," a taxpayer may pay any taxes, duties, fees, levies, charges, penalties or fines due under any revenue Act through that intermediary, and the intermediary must credit the Consolidated Revenue Fund with the full amount within 24 hours (shortened from 48 hours by Act 7/2024 w.e.f. 1 January 2025). An intermediary that delays without valid reason becomes liable to interest of 15% on US-dollar amounts, or the bank policy rate plus 5% on Zimbabwe-dollar amounts. This is the statutory spine of "agent collection" that makes the transaction levies enforceable.

C1. The IMTT in depth — what is, and is not, a taxable transaction

The IMTT is the levy a Zimbabwean business meets most often, so it repays close study. The charge under Section 36G(2) bites on a "transaction on which the tax is payable." That defined term is built negatively: the Thirtieth Schedule says it "does not include" a long list of transactions. Everything not on the exclusion list, that passes through a financial institution, is taxable at 2% (US$0.02 per dollar/ZiG/token), capped at US$10,150 for transactions ≥ US$500,000.

Work through the exemptions confirmed in the Thirtieth Schedule — each exists for a reason:

• (a) marketable securities; (b) money-market instruments — to avoid taxing capital-market settlement, which would cascade and distort yields.
• (bb) Designated Special Purpose Accounts of Implementing Partners under the Privileges and Immunities Act — diplomatic/aid immunity.
• (c) payment of remuneration — wages and salaries are not "money transfers" in the mischief sense; taxing payroll would be a second tax on labour already bearing PAYE.
• (cc) transfers to growers of wheat, maize and small grains by the GMB or approved commercial buyers — food-security policy.
• (d) transfers to or from ZIMRA for the payment or refund of any tax, duty or charge — the State does not tax payments of tax to itself.
• (dd) Global Compensation Deed payments to listed former-farm owners — a politically negotiated carve-out.
• (e) intra-corporate transfers between a company's treasury account and its own trading accounts — internal movements of one entity's own money are not "transfers" to another person.
• (f) transfers from (but not into) specified trust accounts — note the asymmetry: paying out of a trust account is exempt, paying in is not.
• (h) Government transfers from the Consolidated Revenue Fund or statutory funds.
• (i) transfers to a pension fund or to its beneficiaries — protects retirement savings.
• (j) procurement, production or sale of petroleum products by a licensed petroleum company — fuel already bears carbon tax and the petroleum importers levy.
• (k) transfers between an individual's mobile wallet and his or her own bank account — moving your own money between your own accounts.
• (l) medical-aid society payments to a medical service provider in settlement of a claim.
• (m) insurance premium flows from brokers to insurers and from insurers to reinsurers/asset managers.
• (n) MMCZ payments to mineral producers/sellers/exporters; (o) gold payments to producers/sellers by Fidelity Printers and Refiners — protect mineral export earnings.
• (p) ZESA successor-company prepayment-trust transfers; (q) travel-agent payments to airlines for air tickets.
• (q1)–(q4) tobacco and cotton value-chain transfers between buyers, auction floors, contractors and growers.
• (q5) social transfers by designated "development partners"; (q6) Afreximbank transfers; (q7) Carbon Tax Sinking Fund transfers; (q8) Agricultural Development Fund transfers.

The mischief the IMTT targets is ordinary commercial and personal payments moving electronically — paying a supplier, settling an invoice, sending money by mobile money. The exemptions all carve out flows that are either (i) not really third-party transfers (intra-corporate, wallet-to-own-bank), (ii) already taxed or about to be (fuel, securities), (iii) policy-protected (food, pensions, medical, minerals), or (iv) payments of or to the State (tax, government funds). When you classify a payment, ask in order: Does the money pass through a financial institution? Is it on the exclusion list? If not, the 2% applies, subject to the US$10,150 cap.

C2. The cap and the "per transaction" mechanic

The IMTT is charged per transaction, not on a monthly aggregate. At 2%, a US$1,000 payment bears US$20; a US$100,000 payment bears US$2,000. But the flat cap of US$10,150 means that once a single transaction reaches US$507,500 the tax stops rising — and the Act fixes the cap as applying to any single transaction equal to or exceeding US$500,000 (at which point 2% would be US$10,000, stepping up to the flat US$10,150). The cap is a deliberate relief for large corporate and capital transactions, which would otherwise face crippling friction; it nudges very large payers toward single large transfers rather than splitting (though anti-avoidance and the IMTT's own structure discourage artificial splitting in the opposite direction).

C3. The carbon tax in depth — a per-litre commodity charge

Unlike the IMTT, the carbon tax has nothing to do with profit or money movement — it is a per-litre charge on petroleum products entering Zimbabwe, designed to (i) raise revenue from fuel and (ii) price the carbon externality of combustion. The charge is collected at import from the State oil procurement entity or licensed bulk importers, so it is embedded in the pump price every motorist and fleet pays. The dual-currency, multi-subsection drafting (US$0.04/litre or 5% CIF whichever greater; 32.5/100 Zimbabwe cents; 74.6/229.4 Zimbabwe cents) reflects successive re-rating during currency reform, and is precisely why the rate must be read for the specific import channel and date rather than memorised as a single number. The visitor's charge (US$10/vehicle/month) is a separate, simple head reaching foreign-registered cars used in Zimbabwe.

C4. The AFTT versus the IMTT — two different transaction taxes

Students conflate the AFTT (Section 36B) and the IMTT (Section 36G). They are distinct:

• The AFTT is charged on cash withdrawals through automated channels (ATMs and the like): US$0.05 per withdrawal (above the US$100 floor, and for withdrawals up to US$1,000), then 1% for withdrawals above US$1,000. Its base is the act of withdrawing cash.
• The IMTT is charged on electronic transfers of money to another person: 2% per dollar, capped. Its base is the transfer, not the withdrawal.

A person who withdraws US$2,000 cash pays AFTT of 1% × US$2,000 = US$20; the same person who instead electronically pays a supplier US$2,000 pays IMTT of 2% × US$2,000 = US$40 (subject to exemptions). Choosing cash to avoid IMTT simply substitutes AFTT — by design, the two taxes close each other's escape routes.

D1. Individuals

Scenario — Tafara, a salaried Harare professional. Tafara earns a salary (already taxed under PAYE; remuneration transfers are IMTT-exempt under Thirtieth Schedule (c)). In a month he:

• pays his child's school fees electronically: US$1,500. Not exempt → IMTT = 2% × 1,500 = US$30.00.
• moves US$800 from his EcoCash wallet to his own bank account: exempt under (k) (wallet-to-own-bank) → IMTT = US$0.
• withdraws US$400 cash from an ATM: AFTT = US$0.05 flat (withdrawal of US$1,000 or less, above the US$100 floor) → US$0.05.
• buys US$60 of fuel: carbon tax and petroleum importers levy are already embedded in the pump price — he pays them invisibly, not as a separate charge.

Tafara's visible levy cost for the month = US$30.00 (IMTT) + US$0.05 (AFTT) = US$30.05, plus the embedded fuel levies. Note that none of this depends on his income-tax position — he pays it whether or not he has taxable income left after PAYE.

D2. SMEs and partnerships

Scenario — Sunrise Hardware (Pvt) Ltd, a Bulawayo SME. In a month Sunrise:

• pays 30 suppliers electronically, total US$120,000 across the transactions, none individually reaching US$500,000 and none exempt → IMTT = 2% × 120,000 = US$2,400.00.
• makes one large stock import payment of US$520,000 to a single overseas supplier (an outbound foreign payment). 2% of US$520,000 would be US$10,400, but the flat cap applies because the transaction exceeds US$500,000 → IMTT capped at US$10,150.00 (a saving of US$250 versus uncapped).
• withdraws US$3,000 cash for petty expenses: AFTT = 1% × 3,000 = US$30.00 (withdrawal above US$1,000).
• pays staff wages of US$25,000: exempt (remuneration) → US$0.
• pays its quarterly provisional income tax of US$8,000 to ZIMRA: exempt under (d) (payments to ZIMRA) → US$0.

Sunrise's levy cost = US$2,400 + US$10,150 + US$30 = US$12,580 for the month — a cash outflow it bears regardless of whether it is profitable. For a low-margin hardware business this transaction-tax load is a material cost of doing business and a planning focus (e.g. consolidating supplier payments, using exempt channels where genuinely available, and structuring large imports to benefit from the cap).

Partnership note: as established in Persons Liable to Income Tax, a partnership is transparent for income tax — the partners are taxed, not the firm. But the transaction levies do not care about transparency: IMTT and AFTT are charged on the firm's bank and wallet transactions as they occur, exactly as for a company. So a partnership feels the levy load the same way an SME company does.

D3. Large corporates and multinationals

Scenario — Zambezi Beverages Ltd, a large manufacturer. Zambezi makes thousands of payments monthly. Its treasury team focuses on three levy levers:

• Intra-corporate exemption (e): Zambezi sweeps cash nightly between its treasury account and its trading accounts. These are exempt intra-corporate transfers — correctly identifying them avoids paying 2% on internal sweeps that could run to millions, a very large saving.
• The US$10,150 cap: Zambezi's large raw-material import payments routinely exceed US$500,000, so each is capped at US$10,150 rather than scaling at 2%. On a US$2,000,000 payment the cap saves US$29,850 (US$40,000 uncapped − US$10,150).
• Carbon and petroleum levies on its fleet: Zambezi's distribution fleet burns large volumes of diesel; the per-litre carbon tax (74.6 Zim cents/litre diesel) and petroleum importers levy (US$0.05/litre) are embedded costs it manages through route and fuel-procurement planning, not through the income-tax return.

If Zambezi is also profitable, it pays corporate income tax at 25% (per Corporate Income Tax) plus the AIDS levy surcharge on that tax `. The income tax and AIDS levy are annual, profit-based; the IMTT, AFTT and fuel levies are continuous, transaction-based. A complete tax budget for a corporate must model both layers.

Illustrative composite (one month, Zambezi):

Item	Base	Rate	Levy
Domestic supplier payments	US$3,000,000 (none ≥ US$500k)	2%	US$60,000
Three import payments (each US$1.2m)	US$3,600,000	2% capped	US$30,450 (3 × US$10,150)
Intra-corporate sweeps	US$5,000,000	exempt (e)	US$0
Cash withdrawals	US$50,000	1% (>US$1,000)	US$500
Total transaction levies			US$90,950

This US$90,950 monthly transaction-levy load is separate from and additional to the company's income tax and AIDS levy.

1. M. Mlilo v Minister of Finance 19-HH-605 (High Court, Zhou J). The Minister purported to increase the IMTT by newspaper notice (5 October 2018) and then by SI 205/2018. The regulations were challenged, "validated" by Act 1/2019 and "re-validated" by Act 7/2019, before Zhou J declared SI 205/2018 — and hence the affected provisions of the Thirtieth Schedule — ultra vires, on the principle that the Minister cannot by statutory instrument enact what only Parliament may enact (rate-setting is a legislative act reserved to the charging Act). Principle: a tax rate must be fixed by Parliament in the charging (Finance) Act, not by ministerial regulation; purported ministerial rate-changes are void. This is the levy-world echo of the income-tax rule that the charge needs a Finance-Act rate (per Gonese in Corporate Income Tax).

2. Gonese I v Minister of Finance and Economic Development 22-HH-265 (High Court). Cited in the source Act as again declaring Section 22E (carbon tax) illegal, on the same family of delegation-of-powers grounds. Principle: the carbon-tax rate, like every levy rate, must rest on a valid Act of Parliament; subsidiary instruments cannot supply or amend the rate. Practitioners should therefore treat carbon-tax rates inserted by SI with caution and confirm their statutory validation.

3. Matewu C v Minister of Finance, Parliament & Attorney-General 24-HH-590 (High Court). Noted in the source Act as the constitutional challenge to the wealth tax (Section 36O), inserted by Act 13/2023. Principle (as flagged): a new levy on the holding of property invites constitutional scrutiny (equality, arbitrary deprivation of property, and the rating-value base). Until the challenge is finally resolved, the wealth tax's collection-by-local-authority mechanism and its US$250,000 threshold operate, but advisers should monitor the litigation. `

The pattern across all three cases is the same and is the single most important case-law lesson here: levy rates live in the charging Act, set by Parliament. Where a Minister has tried to set or raise a levy by SI or notice, the courts have struck it down — and Parliament has then re-enacted it. When you read a levy rate "substituted by SI …," check that the SI was subsequently validated by an Act (as Section 22G's history repeatedly shows).

1. Treating the AIDS levy figure as confirmed source law. The most common error in this very area is to quote "3% AIDS levy / 25.75% effective" as if it were in the Finance Act you are holding. It was not located in the 27 May 2025 source files. State the principle; flag the figure; confirm against the operative amendment before putting it in client advice.

2. Confusing IMTT and AFTT. They are different taxes on different bases (transfer vs withdrawal) at different rates (2% vs US$0.05/1%). Charging IMTT on a cash withdrawal, or AFTT on an electronic transfer, is simply wrong.

3. Missing an IMTT exemption — over-paying. The Thirtieth Schedule exemptions are numerous and specific. Businesses routinely pay 2% on intra-corporate treasury sweeps (e), wallet-to-own-bank transfers (k), payments to ZIMRA (d) or remuneration (c) that are exempt. Over the year this is real money left on the table.

4. Mis-claiming an IMTT exemption — under-paying. The mirror error: treating an ordinary supplier payment as exempt because it "feels internal," or treating a transfer into a trust account as exempt when only transfers from a specified trust account (f) are. ZIMRA audits the exemption claims; an unjustified claim attracts the tax plus penalty and interest.

5. Forgetting the US$10,150 cap. Paying 2% uncapped on a transaction ≥ US$500,000 over-pays. Conversely, assuming the cap applies to a monthly total rather than a single transaction under-pays — the cap is strictly per transaction.

6. Quoting a single carbon-tax rate. Section 22E has multiple subsections with different per-litre figures and currency units for different import channels and dates. Pick the subsection that matches the channel and year; do not average them.

7. Treating SI-imposed rate changes as automatically valid. Given Mlilo and Gonese, a levy rate inserted by statutory instrument may be ultra vires until validated by an Act. Check for the validating Act before relying on an SI rate.

8. Treating the fast-food and plastic-bag surcharges as Income Tax Act levies. They are collected through VAT Act Sections 12F and 12G — a VAT mechanism, not a 36-series income-tax levy. Misclassifying them leads to the wrong return and the wrong collection point.

9. Late remittance by intermediaries. Banks and mobile-money operators collecting these levies must remit within 24 hours under Section 4B or face 15% (USD) / policy-rate + 5% (ZWL) interest. Intermediaries that batch remittances loosely are personally exposed.

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.

• The levy family runs on a three-part structure: a charging Section (ITA Section 36A–36Q), a numbered Schedule (machinery), and a Finance Act rate Section (Section 22A–22S). Read all three together to advise on any levy.
• The AIDS levy is a surcharge on the income tax itself (so it tracks the income-tax bill and is nil where there is no income tax). Its commonly-quoted 3% / 25.75% effective figure was not found in the 27 May 2025 source Acts and is `-flagged — confirm before quoting.
• IMTT (Section 36G; Thirtieth Schedule; FA Section 22G): 2% (US$0.02/dollar/ZiG/token) on transfers, capped at US$10,150 for single transactions ≥ US$500,000, plus 2% on outbound foreign payments. A long exemption list (remuneration, ZIMRA payments, intra-corporate sweeps, wallet-to-own-bank, pensions, medical, securities, fuel, minerals, tobacco/cotton value chains) defines what is not taxable.
• AFTT (Section 36B; FA Section 22B): US$0.05 per withdrawal (≤US$1,000, above the US$100 floor); 1% above US$1,000 — a cash-withdrawal tax distinct from the IMTT, the two together closing each other's escape routes.
• Carbon tax (Section 36E; Twenty-Eighth Schedule; FA Section 22E): a per-litre commodity charge on petroleum products (operative figures include 74.6 Zim cents/litre diesel and 229.4 Zim cents/litre petrol, and the older "US$0.04/litre or 5% CIF whichever greater"), plus US$10/vehicle/month on visitors. Read the right subsection for the channel and year.
• The wider family is real revenue: tobacco (1.5c/0.75c), demutualisation (2.5%), strategic-reserve fuel levy (0.187/0.247 US cents/litre), property/insurance commission (20%), non-executive directors' fees (20%), petroleum importers (US$0.05/litre), bookmakers/punters (3%/10%), wealth tax (1% over US$250,000, capped US$50,000), lithium/dimensional-stone (2%), and the VAT-collected fast-food (1%) and plastic-bag (20%) surcharges.
• Transaction levies are paid regardless of profit and are collected by intermediaries who must remit within 24 hours under Section 4B or bear 15% / policy-rate+5% interest — making collection robust and compliance non-optional.
• Levy rates belong to Parliament: Mlilo 19-HH-605 and Gonese 22-HH-265 struck down ministerial rate-setting as ultra vires; Matewu 24-HH-590 tests the wealth tax constitutionally. Always confirm that an SI-imposed rate was validated by an Act.

Master comparison — the income-based levy family (as at 27 May 2025)

Levy	ITA charging s.	Finance Act rate s.	Base	Confirmed rate	Notes
AIDS levy	not in source	not in source	Income tax payable	`	Surcharge on the tax; not located in 27 May 2025 Acts
IMTT	36G	22G	Money transferred	2%, cap US$10,150 ≥ US$500,000	Thirtieth Schedule exemptions
AFTT	36B	22B	Cash withdrawal	US$0.05; 1% > US$1,000	Above US$100 floor
Carbon tax	36E	22E	Litres of fuel	74.6c diesel / 229.4c petrol per litre (Zim cents); US$10/veh/mo visitors	Multiple subsections
Tobacco levy	36A	22A	Price of tobacco	1.5c buyers / 0.75c sellers per $	Auction & contract tobacco
Demutualisation levy	36D	22D	Member's amount	2.5%	Per Zimbabwean member
Strategic reserve levy	36H	22H	Litres of fuel	0.187c diesel / 0.247c petrol (US cents/litre)	SI 50/2025 w.e.f. 9 May 2025
Property/insurance commission tax	36I	22I	Commission	20%	Estate agents & insurers
Non-executive directors' fees tax	36J	22J	Director's fees	20%	Thirty-Third Schedule
Petroleum importers levy	36K	22L	Litres transported	US$0.05/litre	Road transport of fuel
Bookmakers / punters tax	36L	22M	Gross takings / winnings	3% / 10%	FA(No.2) 7/2024, 1 Jan 2025
Pre-2009 share-option tax	—	22K	Market value at exercise	5%	Transitional
Wealth tax	36O	22O	Dwelling value > US$250,000	1%, cap US$50,000/yr	Local-authority collection; 24-HH-590
Lithium / dimensional-stone levy	36P	22P	Gross value of sale/export	2%	Currency of trade
Mining royalties	36Q	22Q	Mineral value	per Chapter VII	See Mining lesson
Fast-food surcharge	(VAT Section 12F)	22R	Sale value	1%	VAT-collected
Plastic-bag surcharge	(VAT Section 12G)	22S	Sale/CIF value	20%	VAT-collected

IMTT vs AFTT at a glance

Feature	IMTT (Section 36G)	AFTT (Section 36B)
Trigger	Electronic transfer to another person	Cash withdrawal
Base	Amount transferred	Amount withdrawn
Rate	2% (US$0.02/$), cap US$10,150 ≥ US$500,000	US$0.05 ≤ US$1,000; 1% > US$1,000
Key exemptions	Remuneration, ZIMRA payments, intra-corporate, wallet↔own bank, pensions, medical, securities, fuel	Withdrawals ≤ US$100 (below floor)
Schedule	Thirtieth	Twenty-Fifth

Decision tree — is a payment subject to IMTT?

flowchart TD
 A[A payment is made] --> B{Does it pass through a financial institution?}
 B -->|No| C[No IMTT - outside the charge]
 B -->|Yes| D{Is it a cash withdrawal rather than a transfer?}
 D -->|Yes| E[Consider AFTT Section 36B, not IMTT]
 D -->|No| F{On the Thirtieth Schedule exclusion list?}
 F -->|Yes - eg remuneration, ZIMRA, intra-corporate, wallet to own bank, pension, medical, securities, fuel| G[Exempt - no IMTT]
 F -->|No| H{Single transaction at least USD 500000?}
 H -->|Yes| I[Flat IMTT of USD 10150]
 H -->|No| J[IMTT at 2 percent of the amount]

Statutes & sections

• Income Tax Act [Chapter 23:06], Part V — Section 36A (tobacco levy; Twenty-Fourth Schedule); Section 36B (automated financial transactions tax; Twenty-Fifth Schedule); Section 36C (presumptive tax; Twenty-Sixth Schedule); Section 36D (demutualisation levy; Twenty-Seventh Schedule); Section 36E (carbon tax; Twenty-Eighth Schedule); Section 36G (intermediated money transfer tax; Thirtieth Schedule — IMTT charge, ZiG-token definition, Section 36G(3) differential rate); Section 36H (NOCZIM debt-redemption & strategic reserve levy; Thirty-First Schedule); Section 36I (property/insurance commission tax; Thirty-Second Schedule); Section 36J (tax on non-executive directors' fees; Thirty-Third Schedule); Section 36K (petroleum importers levy; Thirty-First Schedule); Section 36L (bookmakers & punters tax; Thirty-Sixth Schedule); Section 36O (wealth tax — US$250,000 threshold, US$50,000 cap, local-authority collection); Section 36P (lithium/black-granite/quarry/dimensional-stone levy); Section 36Q (mining royalties; Thirty-Seventh Schedule). Thirtieth Schedule — IMTT machinery, definition of "financial institution," and the "transaction on which the tax is payable does not include …" exemption list (paras (a)–(q8)).
• Finance Act [Chapter 23:04], Part III — Section 22A (tobacco levy 1.5c/0.75c); Section 22B (AFTT US$0.05; 1% > US$1,000); Section 22C (presumptive tax rates); Section 22D (demutualisation 2.5%); Section 22E (carbon tax per-litre rates and US$10/vehicle/month visitor charge); Section 22G (IMTT 2% / US$0.02 per dollar/ZiG/token, US$10,150 cap ≥ US$500,000, outbound payments; substituted by the Finance Act 2024 w.e.f. 3 May 2024); Section 22H (strategic reserve levy 0.187c/0.247c per litre, SI 50/2025); Section 22I (commission tax 20%); Section 22J (NED fees 20%); Section 22K (5% pre-1 Feb 2009 share-option tax); Section 22L (petroleum importers levy US$0.05/litre); Section 22M (bookmakers 3% / punters 10%); Section 22O (wealth tax 1%, US$50,000 cap); Section 22P (lithium/dimensional-stone 2%); Section 22R (fast-food surcharge 1% via VAT Section 12F); Section 22S (plastic-bag surcharge 20% via VAT Section 12G). Section 4B (prompt remittance by approved financial intermediaries — 24-hour rule; 15% USD / policy-rate+5% ZWL interest on delay).
• Value Added Tax Act [Chapter 23:12] — Sections 12F, 12G (collection mechanism for the fast-food and disposable-plastic-bag surcharges).

Case law

• M. Mlilo v Minister of Finance 19-HH-605 (HC, Zhou J) — SI 205/2018 increasing the IMTT declared ultra vires; levy rates must be fixed by the charging Act, not ministerial regulation.
• Gonese I v Minister of Finance and Economic Development 22-HH-265 (HC) — Section 22E (carbon tax) declared illegal on delegation-of-powers grounds; same principle as Mlilo.
• Matewu C v Minister of Finance, Parliament & Attorney-General 24-HH-590 (HC) — constitutional challenge to the wealth tax (Section 36O). `

ZIMRA guidance

• Comprehensive Guide to the Digital Services WHT Return; Comprehensive Guide to the Gaming Operator Tax Return; Comprehensive Guide to the Levy on Specified Minerals; Comprehensive Guide to the Presumptive Rental Income Tax Return (ZIMRA External Guides) — practical/administrative layer for several of the levies surveyed here (gaming/bookmakers, mineral levies, presumptive heads). Consult the matching guide when advising on a specific levy return.

Verification flags raised in this lesson

• AIDS levy: no discrete charging section or rate found in the Income Tax Act or Finance Act as at 27 May 2025; the 3% rate / 25.75% effective company rate are practitioner-standard but unconfirmed from these sources.
• IMTT ZiG flat-cap threshold: Section 22G as transcribed shows "US$500" for the ZiG branch vs "US$500,000" for the USD branch — likely a drafting/transcription slip; confirm before advising on large ZiG transactions.
• Carbon tax rate: Section 22E contains overlapping subsections (1)/(1a)/(1b) with different per-litre figures and currency units, several inserted by SIs later questioned as ultra vires; confirm the operative subsection for the channel and year.
• Case holdings: facts/holdings drawn from the source Acts' editorial notes; confirm against the law reports before quoting beyond the cited principle.