Vatcompliance

The substantive rules of the preceding lessons — the charge, timing, value, documentation — converge on a periodic act of compliance: the return. Part V of the VAT Act [Chapter 23:12] (Sections 27–31) organises it. Section 27 divides registered operators into four tax-period categories: Category A (two-month periods ending January, March, May, July, September, November), Category B (two-month periods ending February, April, June, August, October, December), Category C (monthly — compulsory for large operators whose 12-month taxable supplies exceed the statutory threshold, available on written application, and imposable on repeat defaulters), and Category D (periods approved on application for operators whose trade consists solely of agricultural, pastoral or other farming activities below the farming threshold, and analogous separately registered branches). The Commissioner allocates A/B so the two categories are approximately equal in number (smoothing national filing flows) and may move operators between them; category-change events must be notified under Section 25 (Registration lesson). The thresholds carry a tangled amendment history (Finance Acts 10 of 2020, 7 of 2021 and 8 of 2022; the Fourth Schedule to SI 273 of 2003) — date-stamp any figure before use.

Section 28 is the operative duty: for every tax period the operator must furnish a return in the prescribed form and calculate and pay the tax (or compute the refund). The statutory deadline has been a moving target: successively extended from 5 to 25 days through 2009–2012, then shortened by Section 33 of the Finance (No. 2) Act 7 of 2024, with effect from 1 January 2025, to the period ending on the 15th day of the first month after the tax period. The 2026 administration layers a tighter operational cycle on top: ZIMRA's Public Notice 23 of 2026 (citing SI 81 of 2025 and the Finance Act 7 of 2025) required Category A and C returns for the period ended 31 March 2026 by 10 April 2026, with payment by 15 April 2026 — returns online on the TaRMS Self-Service Portal, input tax claimed only through FDMS-validated fiscal invoices auto-populated into the Invoice Management Module, VAT withholding certificates attached where Section 50A agents withheld, and payment in the currency of trade. A return is due for every period whether or not tax is payable or a refund is due (Section 28(2) — ZIMRA v Packers International (Pvt) Ltd 16-SC-028); the Commissioner may extend time in particular cases (Section 28(3), subject to Section 38).

The supporting cast: Section 29 (special returns — the seller under a power of sale (Section 7(1) — Imposition lesson) files a prescribed return within 30 days of the sale, pays the tax out of the proceeds, copies the owner, and both exclude the transaction from their Section 28 returns); Section 30 (the Commissioner may demand further or other returns from any person; and — inserted by the Finance (No. 2) Act 7 of 2024, w.e.f. 1 January 2025 — procuring entities (PRAZ, ministries, departments and tender-procuring organisations) must file monthly tender-award returns by the 10th detailing tenders awarded and values); and Section 31 (assessments — the Commissioner's power to fix the liability where returns are absent, incomplete or not credible, examined in the VAT Assessments and Audits lessons). Section 38 governs the manner of payment: tax is paid in full within the Section 13/28/29 time; where the amount cannot be accurately calculated for reasons beyond the operator's control, the Commissioner may accept a deposit of the estimated liability as a provisional payment, trued up on final determination; and the currency rule — payment follows the currency of the underlying trade: foreign-currency receipts oblige foreign-currency VAT remittance (subsection (4), with the editor's note on SI 142 of 2019: the ZWL's legal-tender entrenchment neither invalidates forex receipts nor relieves the forex payment obligation).

Default is priced by Section 39: failure to pay by the deadline attracts a civil penalty equal to 100% of the tax plus interest at the prescribed rate (per Schedule 5 to SI 273 of 2003; SI 53 of 2021 prescribing the foreign-currency interest rate from 26 February 2021) for each month or part-month — the regime applied in VSL (Pvt) Ltd & 3 Ors v ZIMRA 19-HH-023, V v ZIMRA 19-HH-643 and E.J (Pvt) Ltd v ZIMRA 19-HH-528 — with improperly obtained refunds clawed back as deemed unpaid tax carrying the same penalty and interest. The ZIMRA Comprehensive Guide to the VAT 7 documents the return's field-level mechanics, and the 2026 public notices (01, 07, 11 and 23 of 2026) fix the operational calendar at the 15.5% rate era. Compliance, in short, is a four-question discipline each period: which category am I, what goes in the return, by when must I file and pay, and in which currency?

From substantive law to periodic settlement

Every preceding lesson feeds a return field. The charge and deemed supplies (Sections 6–7) generate output tax; time of supply (Section 8) allocates it to a period; value (Section 9) quantifies it; zero-ratings (Section 10) populate the 0% fields with Section 10(3) proof behind them; documentation (Sections 20–21, 57) credentials the input tax (Sections 15–16 — Input Tax lesson); and Section 28 sweeps the period's totals into a single self-assessed settlement: output minus input equals tax payable or refund due. VAT's efficiency as a revenue-raiser rests on this self-assessment cycle — ZIMRA collects from tens of thousands of operators monthly or bi-monthly without assessing any of them first; assessment (Section 31) is the exception, triggered by default or distrust (Audits lesson).

Why categories exist

Categories tune compliance frequency to scale and risk: large operators (Category C) file monthly because the fisc cannot wait two months for their cash; farmers (Category D) get longer cycles fitted to seasonal income; the A/B split staggers the remaining population across alternating months so the filing system (and ZIMRA's processing) is load-balanced — hence the statutory instruction to keep A and B approximately equal. Category C also doubles as a discipline tool: repeat defaulters can be directed into monthly filing where they are watched twelve times a year.

Where this lesson sits

This lesson assumes the Registration lesson (who files at all; Section 25's category-change notifications), the Time of Supply lesson (which period a supply belongs to — including the December 2025/January 2026 rate straddle on Category A's combined return, Public Notice 07 of 2026), the Documentation lesson (the FDMS-validated invoice as the input claim's foundation), and the Input Tax and Refunds lessons (the Section 15 computation and the Section 44 refund machinery). The enforcement sequel — assessments, audits, penalties beyond Section 39, recovery under Part VII — is the VAT Audits & ZIMRA Powers and VAT Assessments lessons' territory; objections to assessments are the Objections lesson's.

B.1 Section 27: the category system

• 27(1) Definitions. Category A — two-month periods ending the last day of January, March, May, July, September and November; Category B — two-month periods ending February, April, June, August, October and December; Category C — one-month periods ending the last day of each month; Category D — periods ending on other approved months, on written application.
• 27(2) Computation rules. Threshold values are computed with the Act's value rules but excluding the tax; and a proviso mirrors the registration proviso: breaches caused solely by cessation/permanent reduction, replacement of plant or capital assets, or abnormal temporary circumstances are disregarded. (The text carries legacy mixed-currency figures — "zw$110 million or US$240,00[0]" — repeatedly amended by FA 10/2020, FA 7/2021 Section 56 and FA 8/2022, and cross-referenced to the Fourth Schedule of SI 273 of 2003. )
• 27(3)–(4) The A/B default. Every operator not in C or D falls in A or B; the Commissioner determines which, keeping the two categories approximately equal in number, and may move an operator from A to B (or vice versa) with effect from a future period.
• 27(5) Category C. An operator falls in C where: (a) 12-month taxable supplies (including those of separately registered Section 51 branches) exceeded the threshold in the trailing 12 months, or are likely to exceed it in the leading 12 months; or (b) the operator applied in writing for monthly periods; or (c) the operator has repeatedly defaulted on Act obligations — and the Commissioner has so directed. The proviso allows exit to A, B or D on written application where circumstances change to the Commissioner's satisfaction.
• 27(6) Category D. Reserved for operators whose trade consists solely of agricultural, pastoral or other farming activities (or Section 23(5)/51(2) branches with solely-farming activities not duplicated elsewhere in the entity), whose farming taxable supplies have not exceeded and are not likely to exceed the farming threshold — on written application (paragraph (e) of the subsection) and Commissioner approval.

B.2 Section 28: the return-and-pay duty

• 28(1) The deadline. Within "the period ending on the 15th day of the first month commencing after the end of a tax period" (or, for periods ending mid-month, by the last day of that month), the operator must: (a) furnish the prescribed return with the information needed for the Section 15 calculation; and (b) calculate and pay the tax (or compute the refund). The deadline's history is itself examinable: substituted by Act 5 of 2009; extended from 5 to 10 days (FA (No. 3) 10 of 2009), to 15 (Act 3 of 2010), to 20 (Act 5 of 2010), to the 25th (FA (No. 2) 9 of 2011, w.e.f. 1 January 2012); then shortened from the 25th to the 15th by Section 33 of the Finance (No. 2) Act 7 of 2024, w.e.f. 1 January 2025.
• The 2026 operational cycle. ZIMRA's notices layer the administered calendar onto the statute: Public Notice 23 of 2026 (citing SI 81 of 2025 and the Finance Act 7 of 2025) set the March 2026 period's return due 10 April 2026 and payment due 15 April 2026, on TaRMS; Public Notice 01 of 2026 set the December 2025 cycle.
• 28(2) Nil and refund returns too. Every Part IV-registered operator files for every period "whether or not tax is payable or a refund is due" — the obligation breached in ZIMRA v Packers International (Pvt) Ltd 16-SC-028. Dormancy is not exemption; the nil return is itself the compliance.
• 28(3) Extension. The Commissioner may, on the circumstances of a case but subject to Section 38, extend the furnishing or payment period — a discretion, applied for prospectively, never presumed.

B.3 Sections 29–30: special and other returns

• Section 29. Where Section 7(1) deems goods sold under a power of sale to be supplied in the course of a trade, the seller (sheriff, secured creditor, landlord — registered or not) must within 30 days of the sale: file the prescribed return showing the seller's and owner's details and registration numbers, the date, description and quantity, the selling price and the tax charged under Section 6(1)(a), and other required particulars; pay the tax; and copy the return to the owner. Both seller and owner then exclude the transaction from their own Section 28 returns — the special return is a complete, self-contained settlement of that supply (Imposition lesson C.3; the auctioneer analogue runs through Section 56's machinery — Industry-Specific lesson).
• Section 30(1). The Commissioner may require any person — operator or not, on his own behalf or as agent or trustee — to furnish further or other returns in prescribed form as required.
• Section 30(2) (inserted by FA (No. 2) 7 of 2024, w.e.f. 1 January 2025). The Procurement Regulatory Authority of Zimbabwe, Government ministries and departments, and any company or organisation procuring through tender must submit, by the 10th day after every month, a return detailing tenders awarded and their values in the preceding month. The provision is an information-matching tool: tender awards are cross-checked against the winners' VAT (and registration) profiles — unregistered or under-declaring tender winners surface mechanically.

B.4 Section 31: the assessment backstop (orientation)

Section 31 empowers assessment for the purposes of Part III, Part VII and the recovery/offence sections where returns are not furnished, or the Commissioner is not satisfied with them. Its mechanics — estimated assessments, the taxpayer's burden (Section 37), additional tax — are treated exhaustively in the VAT Assessments and VAT Audits & ZIMRA Powers lessons; here it suffices that the self-assessment system is shadowed by a unilateral one whenever Section 28 is not honoured.

B.5 Section 38: manner and currency of payment

• 38(1): tax is paid in full within the Section 13, 28 or 29 time (subject to the Section 6(3) excise-uplift and Section 12(4)–(5) customs machinery).
• 38(2)–(3) Deposits: where, for circumstances beyond the person's control, the tax cannot be accurately calculated in time, the Commissioner may accept a deposit of the estimated liability, deemed a provisional payment: excess refundable, shortfall recoverable, once the liability is finally determined.
• 38(4) Currency (inserted Act 6 of 2006; substituted Act 3 of 2009): the operator who receives foreign currency for supplies must account for the VAT in foreign currency — the editor's annotation records that SI 142 of 2019 (the ZWL legal-tender instrument) neither impugns the lawfulness of forex receipts nor relieves the forex payment obligation. The 2026 notices repeat the rule operationally: tax is remitted in the currency of trade, and the FA 7/2025 manual export return keeps USD and ZWG streams separate, never netted (Imports & Exports lesson).

B.6 Section 39: penalty and interest

• 39(2)(a): failure to pay Section 28(1) tax in time attracts (i) a penalty equal to the amount of the tax (100%) and (ii) interest at the prescribed rate for each month or part of a month from the first day of the month after the payment month ended (subject to Section 46's additional-tax interactions). The prescribed rates live in Schedule 5 to SI 273 of 2003, with the foreign-currency interest rate prescribed by SI 53 of 2021 (from 26 February 2021) — forex debts bear forex interest. VSL (Pvt) Ltd 19-HH-023, V v ZIMRA 19-HH-643 and E.J (Pvt) Ltd 19-HH-528 are the annotated authorities on the penalty's application.
• 39(2)(b) Refund clawback: where a Section 44 refund (read with Section 15(6)) was not properly refundable, the improper amount is deemed unpaid tax — penalty and interest run as if it had been tax due, from the refund period.
• 39(3): the Section 29 special-return defaulter bears the same structure. Remission and the interaction with criminal sanctions and Section 46 additional tax belong to the Audits and Assessments lessons; Public Notice 23 of 2026's warning — "penalties, interest and prosecutions" — captures the stack.

C.1 Operating the category system

The operator's category determines its periods, and Section 8 (time of supply) determines which period a transaction enters; the two never bend to cash-flow convenience. Category A's defining quirk is the combined December/January return spanning the calendar year-end — which is why the 1 January 2026 rate change made Category A the notices' focus: one return, two rates, month-split computation (Public Notice 07 of 2026; Time of Supply lesson C.6). Movement between categories happens four ways: Commissioner's A/B reallocation (Section 27(4)(b)); growth past the threshold into C (Section 27(5)(a)); election into C or D (Sections 27(5)(b), 27(6)); and discipline into C (Section 27(5)(c)). Each move takes effect from a future period, and the operator's own duty is the Section 25(d) notification when a category-changing event occurs (Registration lesson).

C.2 The return as computation: what Section 28(1)(a)–(b) actually demands

The "information required for the purpose of the calculation of tax in terms of section fifteen" is the VAT 7's content (the ZIMRA Comprehensive Guide to the VAT 7 walks the fields): standard-rated outputs and output tax (at 15.5% from 1 January 2026), zero-rated outputs (exports and domestic zero-ratings separately), exempt and out-of-scope amounts, imported-services declarations, input tax (FDMS-auto-populated from 1 January 2026, with the Invoice Management Module the claiming interface), adjustments (Sections 17, 21 — change-in-use, credit/debit notes), VAT withholding credits (certificate schedules attached), and the net payable or refundable. The FA 7/2025 10% export band files on its own manual return beside the VAT 7 (Imports & Exports lesson). Self-assessment means the operator does the law's work: every figure is a legal conclusion (charge, time, value, rate, credit) the operator certifies.

C.3 The currency discipline

Zimbabwe's multi-currency reality is handled by stream separation: the VAT follows the money. USD receipts → USD output tax → USD remittance; ZWG receipts → ZWG remittance; no cross-currency netting (a USD refund position cannot extinguish a ZWG liability on the same return). Interest follows the same logic (SI 53/2021's forex rate). For mixed-currency retailers the practical demands are till-level currency capture, currency-tagged FDMS data, and two payment instructions per period.

C.4 The cost of default: a worked stack

A Category C operator owes USD 10,000 for March 2026 (return due in the April cycle) and pays four months late, having filed nothing. The stack: tax USD 10,000; Section 39(2)(a)(i) penalty USD 10,000 (100%); interest at the prescribed forex rate for each month or part-month from 1 May 2026 (); plus exposure to a Section 31 estimated assessment (filed nothing), Section 46 additional tax in assessment cases, late-filing consequences, and — per the notices — possible prosecution. The 100% penalty is the headline: late VAT roughly doubles, before interest. Remission practice (grounds, conduct, first-offence factors) is the Audits lesson's subject; the planning point here is brutal arithmetic — short-term funding at commercial rates is always cheaper than the fisc's penalty.

C.5 Special returns as ring-fenced settlements

Section 29's design isolates forced sales from both parties' ordinary returns: the seller-under-power (who may not even be an operator) settles the tax out of the proceeds within 30 days, the owner gets a copy (his proof of what happened to his goods and tax), and both exclude the transaction from Section 28 returns — no double counting, no orphaned output. The same ring-fencing logic appears in the auctioneer machinery (Section 56(6)) and the agent-import value rule (Section 9(22)) — the Act repeatedly prefers a complete settlement at the transaction's edge over reconciliation inside two parties' returns.

D.1 Individuals and sole traders

Scenario 1 — the dormant month. Tsitsi (Category C, registered consultant) makes no supplies in June 2026. She must still file the nil return for June by the July deadline (Section 28(2); Packers International). Skipping it invites the late-return consequences and flags her for Section 31 estimation.

Scenario 2 — the sheriff's sale. The sheriff sells Tonde's attached workshop equipment for USD 5,775 (no non-taxability statement given — Imposition lesson). Within 30 days the sheriff files the Section 29 special return (his details; Tonde's details; date; description; price; tax = 5,775 × 15.5/115.5 = USD 775), pays the USD 775, and sends Tonde a copy; Tonde excludes the sale from any return of his own.

D.2 SMEs

Scenario 3 — choosing categories. Rufaro Farms (solely farming; below the farming threshold) applies in writing for Category D with periods fitted to its marketing seasons. Its sister company, Rufaro Logistics, grows past the Category C threshold during 2026: from the Commissioner's direction it files monthly; its Section 25(d) notification duty arose when the threshold event occurred. A third group member, thrice late in 2025, is directed into Category C under Section 27(5)(c) — monthly filing as supervision.

Scenario 4 — the Category A straddle return. Chipo's Grocers (Category A) files the combined December 2025/January 2026 return: December outputs at 15/115, January at 15.5/115.5, computed separately and summed (PN 07/2026; Time of Supply lesson scenario 5); input tax for January claims only FDMS-validated invoices (PN 11/2026); the return goes through TaRMS by the administered deadline, payment in each currency of trade.

Scenario 5 — the deposit option. Mutoko Mills' systems crash in the cut-over week; it cannot compute April 2026 accurately by the deadline. It applies under Section 38(2) to pay a deposit of its estimated liability (USD 18,000, based on prior periods), conditions imposed; on restoration the true figure is USD 19,400 — the USD 1,400 shortfall is recoverable (with the Section 39 analysis on any late element), and had it overpaid, the excess would be refundable. The deposit is a shield against the 100% penalty on the estimated core, not a holiday.

D.3 Large corporates and public sector

Scenario 6 — the procuring ministry. A ministry awards USD 2.4m of tenders in May 2026. By 10 June 2026 it files the Section 30(2) tender-award return listing awards and values. ZIMRA matches the winners against registration and declaration records: a USD 400,000 winner with no VAT registration meets the Registration lesson's backdating machinery.

Scenario 7 — the multi-currency manufacturer. Kariba Steel invoices 60% USD / 40% ZWG. Each period it computes two output streams, claims FDMS-validated input per currency, attaches its VAT withholding certificate schedules for the Section 50A amounts withheld by its appointed-agent customers (Representative Registered Operators lesson), and makes two payments in the currencies of trade — never netting the USD refund position against the ZWG payable (Section 38(4); the notices' standing instruction).

• ZIMRA v Packers International (Pvt) Ltd 16-SC-028 (Supreme Court). Annotated at Section 28(2): the return obligation exists for every period whether or not tax is payable — the leading authority that filing is itself the duty, independent of liability.
• VSL (Pvt) Ltd & 3 Ors v ZIMRA 19-HH-023; V v ZIMRA 19-HH-643; E.J (Pvt) Ltd v ZIMRA 19-HH-528 (High Court). Annotated at Section 39(2)(a)(i): the application of the 100% penalty (and interest) for failure to pay by the due date — in VSL and E.J riding on zero-rating failures (the supplies reverted to standard rate, and the unpaid difference attracted the penalty stack).

1. "Nothing happened, so no return." Section 28(2) requires the return for every period — nil, payable or refund (Packers International). Dormant and seasonal operators must file or change category/deregister properly.
2. Filing to the old deadline. The 25th-day era ended: FA (No. 2) 7/2024 moved Section 28(1) to the 15th from 1 January 2025, and the 2026 administered cycle (SI 81/2025; PN 23/2026) runs return by the 10th, payment by the 15th — calendar to the current instrument, not to habit ().
3. Treating the rate straddle as one computation. Category A's combined Dec 2025/Jan 2026 return splits 15% and 15.5% by month (PN 07/2026); blended-rate shortcuts misstate both months.
4. Claiming input outside FDMS. From 1 January 2026 manual input schedules are gone (save approval); only "Valid", correctly-addressed fiscal invoices in the Invoice Management Module count (PN 11 and 23 of 2026; Documentation lesson).
5. Netting currencies. USD and ZWG streams are computed, reported and paid separately in the currency of trade (Section 38(4)); cross-currency set-off is not a payment.
6. Ignoring the special-return ring-fence. Power-of-sale sellers must file the Section 29 return within 30 days and pay from proceeds; owners must exclude the transaction from their own returns — double-counting or omission both misstate.
7. Assuming extensions. Section 28(3) extensions are discretionary, prospective and subject to Section 38; the Section 38(2) deposit is the lawful route when accurate computation is genuinely impossible — silence is the route to the 100% penalty.
8. Forgetting withholding credits' paperwork. Where Section 50A agents withheld, the certificate schedules must accompany the return to support the credit — the credit is documentary, like everything else in VAT.
9. Underrating the penalty arithmetic. 100% of the tax plus monthly forex-rate interest (SI 53/2021), plus refund clawbacks deemed unpaid tax (Section 39(2)(b)) — late VAT doubles before interest; fund the payment, then argue.
10. Public-sector blind spots. Procuring entities' Section 30(2) monthly tender returns (by the 10th) are statutory duties with matching consequences for tender winners — both sides of the tender now report.

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.

• Four categories (Section 27): A and B (alternating two-month cycles, Commissioner-balanced), C (monthly — size, election or discipline), D (solely-farming, approved periods). Category events trigger Section 25(d) notification; thresholds are amendment-tracked ().
• Section 28: return and payment each period — statutorily by the 15th day of the following month (FA (No.2) 7/2024, from 1 Jan 2025), administered in 2026 as return by the 10th, payment by the 15th (SI 81/2025; PN 23/2026), online on TaRMS; nil returns compulsory (Section 28(2), Packers International); extensions discretionary (Section 28(3)).
• Special and other returns: Section 29 power-of-sale settlements (30 days; copy to owner; ring-fenced); Section 30(1) Commissioner-required returns; Section 30(2) monthly tender-award returns by procuring entities (by the 10th).
• Section 38: pay in full and on time; deposits of estimated liability where accurate computation is impossible for reasons beyond control (provisional, trued up); currency of trade rule — forex receipts mean forex VAT (SI 142/2019 notwithstanding), streams never netted.
• Section 39: late payment = 100% penalty + monthly interest (Schedule 5 SI 273/2003; SI 53/2021 forex rate) (VSL, V, E.J); improper refunds clawed back as deemed unpaid tax with the same stack.
• The 2026 environment: 15.5% rate; FDMS-only input claims via the Invoice Management Module; withholding certificate schedules attached; Category A's straddle return split by month; the manual 10% export return and manual DST return running alongside.
• Compliance is a system: category → period (Section 8) → computation (Sections 6–17) → documentation (Sections 20–21, 57) → return and payment (Sections 28, 38) — with Section 31 assessment and Part VII recovery waiting behind every gap.

Table 1 — The category system

Table 2 — Default pricing under Section 39 (illustrative, USD stream)

Diagram — the periodic compliance cycle

flowchart TD
 A["Category fixed (Section 27): A / B / C / D"] --> B["Supplies timed into the period (Section 8)"]
 B --> C["Output tax computed (Sections 6, 7, 9, 10): 15.5 percent / 0 percent / 10 percent export band"]
 B --> D["Input tax credentialed: FDMS-validated fiscal invoices in TaRMS (PN 11 and 23 of 2026)"]
 C --> E["Adjustments: Sections 17, 21; withholding certificate schedules (Section 50A)"]
 D --> E
 E --> F["Return on TaRMS by the administered deadline (Section 28(1); SI 81/2025)"]
 F --> G{Payable or refund?}
 G -->|Payable| H["Pay in full, currency of trade, by the deadline (Section 38)"]
 G -->|Refund| I["Refund claim - Section 44 (Refunds lesson)"]
 G -->|Nil| J["Nil return still compulsory (Section 28(2))"]
 H --> K{Paid late or not at all?}
 K -->|Yes| L["Section 39: 100 percent penalty + monthly interest; Section 31 assessment; Part VII recovery"]
 K -->|No| M["Period closed; records retained 6 years (Section 57)"]

Statutes & sections

• Value Added Tax Act [Chapter 23:12] — Section 27 (tax periods: categories A–D; computation rules; allocation; Category C entry/exit; Category D farming conditions); Section 28 (returns and payment: (1) deadline as amended — Act 5/2009; FA (No.3) 10/2009; Act 3/2010; Act 5/2010; FA (No.2) 9/2011; FA (No.2) 7/2024 Section 33 (15th day, w.e.f. 1 Jan 2025); (2) nil returns; (3) extension); Section 29 (special returns — power-of-sale sales); Section 30 ((1) other returns; (2) tender-award returns — FA (No.2) 7/2024); Section 31 (assessments — orientation); Section 38 (manner of payment; deposits; currency — Act 6/2006; Act 3/2009; SI 142/2019 note); Section 39 (penalty equal to tax + prescribed-rate interest; refund clawback). Cross-referenced: Sections 6–17, 20–21, 23(5), 25(c)–(d), 44, 46, 50A, 51, 56, 57.
• VAT (General) Regulations, SI 273 of 2003 — Fourth Schedule (category thresholds); Schedule 5 (prescribed interest rates); SI 53 of 2021 (foreign-currency interest rate, from 26 Feb 2021).
• SI 81 of 2025 and Finance Act 7 of 2025 — the administered 2026 return/payment cycle per ZIMRA Public Notice 23 of 2026.

Case law

• ZIMRA v Packers International (Pvt) Ltd 16-SC-028 — returns due whether or not tax is payable (Section 28(2)).
• VSL (Pvt) Ltd & 3 Ors v ZIMRA 19-HH-023; V v ZIMRA 19-HH-643; E.J (Pvt) Ltd v ZIMRA 19-HH-528 — the 100% penalty and interest (Section 39(2)(a)).

ZIMRA guidance

• ZIMRA, Comprehensive Guide to the VAT 7 — field-level return mechanics.
• Public Notice 23 of 2026 — April 2026 VAT/DST cycle; FDMS input workflow; currency of trade.
• Public Notice 11 of 2026 — categories and FDMS auto-population.
• Public Notice 01 of 2026 — December 2025 period obligations.
• Public Notice 07 of 2026 — the Category A straddle computation.
• ZIMRA, Comprehensive Guide to the VAT Return for Remittance of VAT at 10% (Exports) — the parallel manual export return.