The family home is, for most Zimbabweans, the single largest asset they will ever own — and a house is immovable property, hence a specified asset fully within the capital gains tax net. Without special relief, every family that sold one home to buy another, and every retiree who downsized, would face a 20% capital gains charge on decades of accumulated value. The Capital Gains Tax Act [Chapter 23:01] therefore carves out two distinct, and frequently confused, reliefs for the principal private residence (PPR). This lesson explains both, in detail, and shows exactly when each applies.

The two reliefs operate on completely different principles. The first is a permanent exemption for the elderly: under Section 10(l), "amounts received by a person on the sale of his or her principal private residence … if such person was, on the date of the sale, of or over the age of 55 years" are exempt from capital gains tax — the entire gain disappears, with no cap, no reinvestment condition, and no clawback (the qualifying age was reduced from 59 to 55 by Act 5 of 2009). The second is a deferral (rollover) available to any age: under Section 21, an individual who sells a PPR and reinvests the proceeds in a new PPR (or residential stand) by the end of the following year of assessment pays no CGT to the extent reinvested, but the deferred gain is carried over by reducing the cost base of the new home (Section 21(3)). The over-55 route forgives the tax forever; the reinvestment route only postpones it to the eventual non-reinvested sale.

The definitions matter. A "principal private residence" (Section 21(1)) is a dwelling proved to the Commissioner to have been the individual's sole or main residence — throughout ownership, or for at least 4 years before sale (or a shorter period the Commissioner accepts), or notionally where employment or other accepted cause prevented residence — together with surrounding land used for domestic purposes up to 2 hectares (or more if the Commissioner accepts) and associated garages/outbuildings. A "residential stand" intended for building a PPR also qualifies for the Section 21 rollover. Where the home is sold with non-residential property, or the land/outbuildings are sold separately from the dwelling, apportionment and exclusion rules apply (Section 21(5)–(6)).

The Section 21 rollover formula taxes only the non-reinvested proportion of the gain. Where the consideration is fully reinvested, no CGT is chargeable (Section 21(2)(a)); where only part is reinvested, the chargeable gain is C × (A ÷ B), in which A is the portion of the consideration not reinvested, B is the total consideration, and C is the capital gain on the old PPR (Section 21(2)(b)). The exempted (reinvested) portion then reduces the Section 11(2)(a) cost of the new PPR (Section 21(3)), so the deferred gain resurfaces on a later sale. The election must be made by the date the CGT return is submitted (Section 21(2a)).

A third, related relief sits in Section 16: transfers of a specified asset between spouses, and a transfer of a PPR to a former spouse under a divorce/maintenance court order, may be rolled over at the transferor's carried-forward cost base, with the whole accumulated gain falling on the transferee's eventual sale to an outsider (Section 16(2), proviso). And Section 10(m) gives the over-55 a separate small exemption on marketable securities (the first US$1,800 of proceeds a year) — related in policy but not a PPR relief.

The rate, as always, comes from Finance Act Section 38: a PPR acquired on or after 22 February 2019 is taxed at 20% of the (non-exempt) capital gain, computed in foreign currency under the Section 39A(9a) restricted-deduction rules (acquisition/improvement cost, selling costs, and the 2½%/year allowance in lieu of CPI). This lesson runs worked USD computations for an over-55 outright exemption, a full reinvestment, a partial reinvestment with the cost-base carry-over, and a divorce transfer. It builds on Capital Gains Tax Exemptions (which frames the exemption-versus-rollover distinction), How to Determine Capital Gains (the funnel), Disposal of Assets and Taxable Events (the disposal trigger) and Specified Assets Under Zimbabwe Capital Gains Tax Law (immovable property as a specified asset).

A capital gains tax that fell on the family home with full force would be politically and economically intolerable. Housing is not a speculative investment for most people; it is shelter, and the "gain" on a long-held home is largely inflation rather than real enrichment. A retiree selling the family house to move into something smaller, or a young family trading up as children arrive, has not realised spendable wealth — the proceeds must immediately be ploughed back into another roof. Taxing such transactions at 20% would lock people into unsuitable housing (the "lock-in effect") and erode retirement security. Virtually every CGT system in the world therefore shelters the principal residence in some way, and Zimbabwe is no exception.

Zimbabwe's response is two reliefs with different philosophies, and the single most important thing a student or practitioner must internalise is that they are not the same relief. The over-55 exemption (Section 10(l)) is an act of social policy toward the elderly: it forgives the gain on their home outright. The reinvestment rollover (Section 21) is an act of economic neutrality toward everyone: it defers the gain so that moving house is not itself a taxable event, but recaptures the tax later by lowering the cost base of the replacement home. Confusing the two — for example, assuming an under-55 seller is exempt, or assuming an over-55 seller must reinvest — is the classic error this lesson exists to prevent.

The home is a specified asset because it is immovable property, the first limb of the Section 2 definition (see Specified Assets Under Zimbabwe Capital Gains Tax Law). Its sale is a disposal (an ordinary sale, or a deemed sale on gift/expropriation/divorce; see Disposal of Assets and Taxable Events). Absent relief, the gain would run through the ordinary funnel of How to Determine Capital Gains. The PPR reliefs intervene at two different points of that funnel: Section 10(l) removes the amount at the exemption stage (gross capital amount → capital amount), while Section 21 operates as a deferral mechanism that suppresses the gain now and adjusts the new home's cost base later. ZIMRA scrutinises PPR claims closely because the relief is valuable and the "sole or main residence" test is fact-sensitive — second homes, holiday cottages and buy-to-let properties do not qualify.

The definition of a principal private residence — Section 21(1)

Section 21(1) defines the building blocks. A "dwelling" is "a building, or any part of a building, which is used wholly or mainly for the purpose of residential accommodation." A "principal private residence", in relation to an individual, means a dwelling proved to the Commissioner's satisfaction:

• "(i) to have been that individual's sole or main residence throughout the period that he owned it; or
• (ii) to have been that individual's sole or main residence for a period of 4 years or more immediately before the date of its sale, or for such shorter period … as the Commissioner considers reasonable in all the circumstances; or
• (iii) to have been regarded by that individual as his sole or main residence, even though he was prevented from residing in it … in consequence of his employment or for such other cause as the Commissioner considers reasonable."

The definition extends (subject to Section 21(5)) to associated land: "any land, whether or not … registered as a separate entity in a Deeds Registry, which (i) is owned by the individual; and (ii) surrounds or is adjacent to the dwelling; and (iii) is used … primarily for private or domestic purposes in association with the dwelling; and (iv) does not exceed 2 hectares or such larger area as the Commissioner … is satisfied [is needed] for the reasonable enjoyment of the dwelling as a principal private residence." It also extends to "any garage, storeroom or other building or structure" owned by the individual, forming part of or attached to or associated with the dwelling and used for private/domestic purposes (Section 21(1)(c)).

A "residential stand" (inserted by Act 12/2006 w.e.f. 1 January 2007) is land "owned by the individual" and "proved … to be intended for the building of a principal private residence thereon" — bringing vacant plots bought to build the family home within the rollover.

The reinvestment rollover — Section 21(2)–(6)

Section 21(2) (substituted by Finance Act 1/2019, backdated to 1 January 2007) gives the relief. An individual "may elect that, where a capital gain has … accrued to him or her … in respect of the sale … of his or her principal private residence or residential stand (the 'old' residence/stand) and the Commissioner is satisfied that, before the end of the year of assessment next following the sale, an amount equal to the whole or part of the consideration … has been or will be expended on the purchase or construction, on land owned by him or her in Zimbabwe, of another principal private residence or residential stand (the 'new' residence/stand)":

• (a) "capital gains tax shall not be chargeable, if the amount of the consideration so received … is equal to or less than the amount so expended"; and
• (b) "capital gains tax shall be chargeable, if the … consideration … exceeds the amount so expended, on a proportion of the capital gain determined by applying the following formula", where A = "that portion of … the consideration … not so expended", B = "the total amount of the consideration", and C = "the capital gain in respect of the sale of the old" residence.

So the chargeable gain is C × (A ÷ B) — the capital gain multiplied by the fraction of the proceeds not reinvested.

Section 21(2a) fixes the timing: "An election in terms of subsection (2) shall be made not later than the date on which the individual … submits a return for the assessment of his capital gain." Section 21(3) supplies the carry-over: where an amount is not chargeable under Section 21(2), "such amount shall be deducted from the amount referred to in Section 11(2)(a) when determining the capital gain in respect of the new principal private residence" — i.e. the rolled-over gain reduces the cost base of the new home, so it resurfaces on the eventual non-reinvested sale. Section 21(4) deems share-block/condominium occupation rights acquired or relinquished through membership to be a purchase or sale of the unit. Section 21(5) disapplies the relief where the land or outbuildings are "disposed of separately from the dwelling". Section 21(6) apportions, by agreed statement or Commissioner determination, where a PPR is sold "together with or as part of other immovable property which is not used wholly or mainly for … residential accommodation."

The over-55 permanent exemption — Section 10(l)

Section 10(l) exempts "amounts received by a person on the sale of his or her principal private residence as defined in subsection (1) of section twenty-one if such person was, on the date of the sale, of or over the age of 55 years." This is a complete exemption of the gain, sitting at the exemption rung of the funnel (gross capital amount → capital amount). There is no monetary cap, no reinvestment requirement, and no clawback. The qualifying age was reduced from 59 to 55 by Section 18 of Act 5 of 2009. The only conditions are that the property meet the Section 21(1) PPR definition and that the seller be 55 or over on the date of sale.

Transfers between spouses and on divorce — Section 16

Section 16 allows a rollover on transfers between spouses. Where "(a) the ownership of any specified asset is transferred from a person to his or her spouse; or (b) a person transfers the ownership of a specified asset which is his principal private residence to his former spouse in compliance with an order of a court providing for maintenance or dividing the assets of the former spouses on or after the dissolution of their marriage", the transferor and transferee "may elect that … the selling price … shall in relation to the transferor be deemed … to be an amount equal to the sum of the deductions allowable to the transferor in respect of the specified asset under Section 11(2)(a)–(d) at the date of transfer." In other words, the transfer is at cost-base value — no gain, no loss. A proviso preserves the deferred gain: "if after the transfer such asset is sold to a person who is not the spouse, the capital gain … shall be calculated as if the asset had at all times remained in the ownership of the first transferor." The election is made by the return date (Section 16(3)).

The over-55 securities exemption — Section 10(m) (related, not PPR)

For completeness, Section 10(m) exempts, for a person 55 or over, "the first … US$1,800 received or accruing … in the year of assessment" on the sale of a marketable security (other than the Section 10(j)-type). This is a separate elderly-relief on shares, not on the home; mention it so as not to confuse it with the PPR reliefs.

Sub-concept 1 — exemption versus rollover (the master distinction)

Capital Gains Tax Exemptions establishes the governing distinction, and the PPR is the place it bites hardest because the home enjoys both kinds of relief:

• An exemption (Section 10(l)) removes the gain permanently. Nobody ever pays CGT on it. No base is carried forward, because there is nothing left to tax.
• A rollover (Section 21) defers the gain. The seller pays nothing now (to the extent reinvested), but the relieved amount is subtracted from the new home's cost base (Section 21(3)), so the same gain — plus any further appreciation — is taxed when the new home is eventually sold without reinvestment.

The diagnostic question is: if the relieved gain is "saved" today, does anyone ever pay it? For Section 10(l) the answer is no (forgiven); for Section 21 the answer is yes, later (deferred). Getting this right determines whether the new home's cost base must be adjusted.

Sub-concept 2 — what qualifies as a "principal private residence"

The relief attaches only to a sole or main residence, proved to the Commissioner. Three routes satisfy the test: continuous main-residence use throughout ownership (Section 21(1)(a)(i)); main-residence use for at least four years before sale, or a shorter Commissioner-accepted period (ii); or deemed residence where employment or other accepted cause kept the owner away (iii). The relief extends to the curtilage — up to two hectares of domestic-use land (more at the Commissioner's discretion) and associated garages/outbuildings — and to a residential stand bought to build the home on. Crucially, a second home, holiday cottage or rental property is not a PPR: it fails the "sole or main residence" test, and its gain runs through the ordinary funnel at the full 20%. Where the land or outbuildings are hived off and sold separately from the dwelling, Section 21(5) denies the relief to that separate disposal; and where the home is bundled with non-residential property, Section 21(6) apportions the proceeds (and the buyer's cost) between the residential and non-residential parts.

Sub-concept 3 — the reinvestment mechanics (Section 21)

The Section 21 rollover rewards continuity of home ownership. Its conditions are: (i) the old property is a PPR or residential stand; (ii) the seller elects by the return date (Section 21(2a)); (iii) the consideration is expended on a new PPR/stand on land owned in Zimbabwe; and (iv) the spending occurs by the end of the year of assessment following the sale. Then:

• Full reinvestment (new spend ≥ proceeds): no CGT (Section 21(2)(a)).
• Partial reinvestment (new spend < proceeds): tax on C × (A ÷ B) — the gain scaled by the unspent fraction of the proceeds (Section 21(2)(b)).
• Cost-base carry-over: the relieved amount reduces the new home's Section 11(2)(a) cost (Section 21(3)), so a future non-reinvested sale recaptures it.

The logic is elegant: you are taxed now only on the cash you took out of the housing market (the unspent proceeds), and the rest is deferred until you finally cash out for good.

Sub-concept 4 — divorce and inter-spouse transfers (Section 16)

Marriage breakdown forces home transfers that are not commercial sales. Section 16 prevents a CGT charge on a transfer between spouses, or on a PPR transferred to a former spouse under a court order on divorce, by deeming the transfer to occur at the transferor's cost base (Section 11(2)(a)–(d) deductions) — no gain, no loss. The deferred gain is preserved by the proviso: when the transferee later sells to an outsider, the gain is computed as if the asset had always been owned by the original transferor, so the full accumulated gain (including the pre-transfer period) is then taxed. This is a rollover, not an exemption — the tax is postponed to the outsider sale, not forgiven.

Step-by-step framework — taxing the sale of a home

1. Is it a PPR? Apply the Section 21(1) sole-or-main-residence test (and the 2-hectare/outbuilding limits). If not (second home, rental), go to the ordinary funnel — no PPR relief.
2. Is the seller 55+ on the date of sale? If yes → Section 10(l) exempts the entire gain; stop.
3. If under 55 (or Section 10(l) not claimed), is the sale a spouse/divorce transfer? If yes → Section 16 rollover at cost base (elect by return date), gain deferred to outsider sale.
4. Otherwise, is the consideration reinvested in a new PPR/stand by the end of the next year? If fully → no CGT (Section 21(2)(a)); if partly → tax C × A/B (Section 21(2)(b)), and reduce the new home's cost base by the relieved amount (Section 21(3)).
5. No relief available? Run the ordinary funnel (How to Determine Capital Gains) and apply the Section 38 rate.

Individual over 55 — outright exemption (Section 10(l))

Facts. Mr Ncube, aged 62, sells the Bulawayo house he has lived in for 20 years for USD 250,000; he bought it for USD 40,000. He is over 55 on the date of sale, and the house meets the PPR definition.

Step	Analysis	CGT
PPR?	Yes — sole/main residence throughout ownership (Section 21(1)(a)(i))	—
Age 55+?	Yes (62) → Section 10(l) exempts the entire amount	—
CGT payable	The whole gain is exempt; no reinvestment needed, no cap	0

Mr Ncube pays nothing, regardless of the size of the gain or whether he buys another home. (For the Section 30A transfer, ZIMRA will issue a clearance certificate confirming the exempt status; the conveyancer obtains it before transfer.)

Individual under 55 — full reinvestment (Section 21(2)(a))

Facts. Chipo, aged 40, sells her Harare PPR (acquired 2020 for USD 90,000) in 2026 for USD 180,000 and, within the following year, spends USD 200,000 building a larger family home on land she owns. She elects Section 21 by her return date.

Because the consideration (USD 180,000) is fully reinvested (USD 200,000 ≥ 180,000), Section 21(2)(a) applies: no CGT is chargeable. However, under Section 21(3) the relieved gain reduces the cost base of the new home. Her gain on the old home was USD 180,000 − 90,000 − (2½%/yr allowance) ≈ a gain of roughly USD 76,500 (90,000 cost; 90,000 × 2.5% × 6 yrs = 13,500 allowance; 180,000 − 90,000 − 13,500 = 76,500). That USD 76,500 is deducted from the new home's Section 11(2)(a) cost, so if she later sells the new home without reinvesting, the deferred gain resurfaces.

Item	USD
Proceeds of old PPR	180,000
Reinvested in new PPR	200,000
CGT now (full reinvestment, Section 21(2)(a))	0
Deferred gain carried to new home (reduces its cost base, Section 21(3))	≈ 76,500

Individual under 55 — partial reinvestment (Section 21(2)(b))

Facts. Same as Chipo, but she reinvests only USD 120,000 of the USD 180,000 proceeds (keeping USD 60,000). Her capital gain on the old PPR (C) is USD 76,500 (as above).

Apply C × (A ÷ B), where A = unspent proceeds = USD 60,000; B = total proceeds = USD 180,000; C = USD 76,500.

Line	Item	USD
1	Capital gain on old PPR (C)	76,500
2	Unspent proceeds (A)	60,000
3	Total proceeds (B)	180,000
4	Chargeable proportion = C × A ÷ B = 76,500 × 60,000 ÷ 180,000	25,500
5	CGT at 20% (Finance Act Section 38(b)(ii))	5,100
6	Relieved (deferred) gain = 76,500 − 25,500 = 51,000 → reduces new-home cost base (Section 21(3))	51,000

Chipo pays USD 5,100 now — tax on the one-third of the gain matching the one-third of proceeds she took out of housing (USD 60,000 ÷ 180,000) — and defers the other USD 51,000 into the new home's cost base.

Divorce transfer (Section 16)

Facts. On divorce, a court orders Tatenda to transfer the matrimonial home (his cost base under Section 11(2)(a)–(d) = USD 70,000; current market value USD 160,000) to his former wife. They elect under Section 16.

Under Section 16(2)(b), the selling price is deemed to equal Tatenda's cost base (USD 70,000) — so no gain accrues to Tatenda on the transfer (no CGT now). By the proviso, when the former wife later sells to an outsider, her gain is computed as if the home had always been owned by Tatenda — i.e. from the original USD 70,000 base — so the full accumulated gain is taxed then. The divorce transfer is thus tax-neutral, with the liability rolled to the eventual market sale. (If the former wife is 55+ when she sells, she could then claim the Section 10(l) exemption in her own right.)

The PPR reliefs are heavily definitional and discretionary (the Commissioner must be "satisfied" of sole-or-main-residence status, reasonable land area, and reinvestment), so disputes turn on fact-finding and the Commissioner's determinations, which are objectionable under Section 25 (see How to Object and Appeal a CGT Assessment).

• Sabeta M v Commissioner-General: ZIMRA 12-HH-079. Although a transfer-gate case, it is directly relevant to PPR practice: once the CGT position on a home sale is settled (including a nil position under Section 10(l) or Section 21), ZIMRA must issue the clearance certificate so the Section 30A transfer can proceed. A PPR seller who has properly claimed relief is entitled to the certificate.
• Old Mutual Zimbabwe Ltd v Commissioner-General of ZIMRA 16-HH-143. Reinforces that relief depends on the statutory conditions being met, not on the taxpayer's characterisation; a property that fails the "sole or main residence" test is not rescued by calling it a home.

The source materials contain no Zimbabwean case squarely construing the Section 21(1) "sole or main residence" limbs or the Section 21(2) reinvestment formula; those operate as statute and turn on the Commissioner's factual satisfaction. A student should resist inventing or importing a foreign "main residence" authority; where guidance is needed, reason from the statutory text and the exemption/rollover distinction.

1. Confusing the over-55 exemption with the reinvestment rollover. Section 10(l) forgives the gain (over-55, no reinvestment, no cap); Section 21 defers it (any age, requires reinvestment, reduces the new home's cost base). Applying one's conditions to the other is the defining error of this topic.
2. Claiming PPR relief for a second home or rental. Only the sole or main residence qualifies. Holiday cottages, buy-to-lets and investment flats fail the Section 21(1) test and are taxed in full.
3. Missing the election deadline. Both the Section 21 rollover and the Section 16 spouse election must be made by the date the CGT return is submitted (Sections 21(2a), 16(3)). A late election forfeits the relief.
4. Forgetting the cost-base carry-over. After a Section 21 rollover, the new home's Section 11(2)(a) cost is reduced by the relieved gain (Section 21(3)). Practitioners who later compute the new home's gain from its full purchase price understate the gain and under-pay.
5. Reinvesting too late or outside Zimbabwe. The spend must be "on land owned by him or her in Zimbabwe" and completed (or contracted) by the end of the next year of assessment. Foreign reinvestment, or a delayed build, breaks the relief.
6. Selling land or outbuildings separately. Under Section 21(5), disposing of the curtilage land or a garage separately from the dwelling denies PPR relief on that separate sale.
7. Over-claiming the land area. The automatic relief covers up to 2 hectares; a larger area needs the Commissioner's satisfaction as to reasonable enjoyment. Estates and smallholdings beyond domestic use are not all PPR.
8. Assuming a divorce transfer is tax-free forever. Section 16 is a rollover, not an exemption — the gain is deferred to the transferee's eventual outsider sale and computed from the original owner's base.

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.

• A home is immovable property and therefore a specified asset fully within CGT; two distinct reliefs shelter it, and they must not be conflated.
• Section 10(l) — over-55 exemption: an individual 55 or over on the date of sale pays no CGT on the gain on a principal private residence — no cap, no reinvestment, no clawback (age reduced 59→55 by Act 5/2009). This is a permanent exemption.
• Section 21 — reinvestment rollover (any age): reinvest the consideration in a new PPR/stand in Zimbabwe by the end of the following year and elect by the return date; full reinvestment → no CGT (Section 21(2)(a)); partial → tax C × (A ÷ B) on the unspent proportion (Section 21(2)(b)); and the relieved gain reduces the new home's cost base (Section 21(3)). This is a deferral, not forgiveness.
• A "principal private residence" (Section 21(1)) is a sole or main residence (throughout ownership, 4 years before sale, or notionally during employment-related absence), plus up to 2 hectares of domestic land and associated outbuildings; a residential stand intended for the home also qualifies. Second homes and rentals do not qualify.
• Section 16 rolls over transfers between spouses and PPR transfers to a former spouse under a divorce court order at the transferor's cost base (no gain, no loss), deferring the whole gain to the transferee's eventual outsider sale.
• Section 10(m) separately exempts the over-55's first US$1,800/year of marketable-security proceeds — a securities relief, not a PPR relief.
• The rate is Finance Act Section 38: a post-22-February-2019 home is taxed at 20% of the (non-exempt) capital gain, computed in foreign currency under Section 39A(9a) (cost, improvements, selling costs, 2½%/yr allowance).
• Policy insight: the over-55 exemption protects retirement security; the reinvestment rollover preserves housing mobility by ensuring that moving home is not itself a taxable event. Both reflect the principle that taxing shelter, or inflation masquerading as gain, would do more economic harm than the revenue is worth.

Table 1 — The two PPR reliefs compared

Dimension	Section 10(l) over-55 exemption	Section 21 reinvestment rollover
Who qualifies	Individual 55+ on date of sale	Individual of any age
Core condition	PPR status only	Reinvest consideration in new PPR/stand in Zimbabwe by end of next year
Election needed?	No (it is an exemption)	Yes, by the return date (Section 21(2a))
Effect on the gain	Forgiven permanently	Deferred (only unspent proportion taxed)
Monetary cap	None	None, but tax on C × A/B if partial
New-home cost base	n/a	Reduced by relieved gain (Section 21(3))
Later recapture?	Never	Yes — on eventual non-reinvested sale

Table 2 — Section 21 reinvestment outcomes

Scenario	Reinvested vs proceeds	CGT now	Cost-base carry-over
Full reinvestment	Spend ≥ proceeds	Nil (Section 21(2)(a))	Whole relieved gain reduces new base
Partial reinvestment	Spend < proceeds	C × (A ÷ B) at 20% (Section 21(2)(b))	Relieved portion reduces new base (Section 21(3))
No reinvestment	No new PPR	Full gain taxed (ordinary funnel)	None
Land/outbuilding sold separately	n/a	No PPR relief (Section 21(5))	n/a

Diagram 1 — Determining CGT on the sale of a home

flowchart TD
 A[Sale of a dwelling] --> B{Sole or main residence Section 21 1}
 B -->|No second home or rental| C[Ordinary funnel 20% on gain]
 B -->|Yes a PPR| D{Seller 55 plus on date of sale}
 D -->|Yes| E[Section 10 l entire gain exempt no CGT]
 D -->|No| F{Spouse or divorce-order transfer}
 F -->|Yes| G[Section 16 rollover at cost base gain deferred to outsider sale]
 F -->|No| H{Consideration reinvested in new PPR by end of next year}
 H -->|Fully| I[Section 21 2 a no CGT reduce new home cost base]
 H -->|Partly| J[Section 21 2 b tax C times A over B reduce new base by relieved part]
 H -->|Not at all| C
 E --> K[Obtain Section 30A certificate to transfer]
 G --> K
 I --> K
 J --> K
 C --> K

Statutes & sections

• Capital Gains Tax Act [Chapter 23:01] — Section 21(1) (definitions of "dwelling", "principal private residence" (3 limbs + 2-hectare land + outbuildings), "residential stand"); Section 21(2) (reinvestment rollover — full relief if consideration ≤ reinvestment; partial charge C × A/B if not; substituted by Finance Act 1/2019 backdated to 1 Jan 2007); Section 21(2a) (election by return date); Section 21(3) (relieved amount reduces the new home's Section 11(2)(a) cost base); Section 21(4) (share-block/condominium occupation rights deemed purchase/sale); Section 21(5) (no relief where land/outbuildings sold separately); Section 21(6) (apportionment where PPR sold with non-residential property); Section 10(l) (over-55 PPR exemption — entire gain, no cap; age 59→55 by Act 5/2009); Section 10(m) (over-55 first US$1,800/yr of marketable-security proceeds — related securities relief); Section 16 (spouse and divorce-order PPR transfers rolled over at cost base; proviso preserves gain to outsider sale; election by return date); Section 11(2)(a)–(d) (the deductions that fix the carried-over cost base); Section 30A (transfer gate — clearance certificate before registration).
• Finance Act [Chapter 23:04] — Section 38(b) (20% of the capital gain for a PPR acquired on/after 22 Feb 2019; 5% of gross for pre-2019); Section 39A(9a) (foreign-currency deduction restriction and 2½%/yr-of-cost allowance).
• Income Tax Act [Chapter 23:06] — Section 8(1) (the income-tax boundary the gross capital amount excludes).

Case law

• Sabeta M v Commissioner-General: ZIMRA 12-HH-079 — once the CGT position on a home sale is settled (including nil under Section 10(l)/Section 21), ZIMRA must issue the Section 30A clearance certificate to permit transfer.
• Old Mutual Zimbabwe Ltd v Commissioner-General of ZIMRA 16-HH-143 — relief depends on the statutory conditions being met, not on the taxpayer's label; "capital" is not tax-free.

ZIMRA guidance

• Comprehensive Guide to Form CGT 1 — ZIMRA External Guide — the CGT 1 return on which a PPR sale (and any Section 10(l)/Section 21 claim) is declared; a wholly exempt Section 10(l) sale and the rollover election are processed through it.