Vatdefinitions

Most provisions of the VAT Act [Chapter 23:12] are short; the definitions that power them are long. Section 2 (Interpretation) is the Act's dictionary, and it is not a passive glossary: in VAT, the definitions are the law. The charging provision in Section 6(1)(a) — analysed in the preceding lesson, VAT Imposition — the Charge — taxes "the supply by any registered operator of goods or services … in the course or furtherance of any trade". Every operative word in that phrase ("supply", "registered operator", "goods", "services", "trade") is a Section 2 defined term, and each definition has been litigated. Reading the Act without Section 2 open beside it is the single most common cause of wrong VAT answers.

This lesson works through the defined terms systematically, clustered by function. The charge cluster drives Section 6: "supply" ("all forms of supply, irrespective of where the supply is effected" — Mylo (Pvt) Ltd v ZIMRA 16-HH-717 on barter), "goods" (corporeal movables, fixed property and real rights, excluding money, mortgage/pledge rights and revenue stamps — MMI (Pvt) Ltd v ZIMRA 19-HH-700 on mining-claim rights), "services" ("anything done or to be done" — Travel agents T (Pvt) Ltd v ZIMRA 15-HH-285), "trade" (continuous or regular activity in Zimbabwe for consideration, "whether or not for profit", with five boundary provisos — GTO Association v ZIMRA 19-HH-464), "registered operator" (any person who is or is required to be registered), "consideration" (any payment, act or forbearance, in money or otherwise, from the recipient or any other person, excluding unconditional gifts — Law Society of Zimbabwe v ZIMRA 18-HH-409), "taxable supply" (chargeable under Section 6(1)(a), including at the zero rate), "exempt supply" (exempt under Section 11), "output tax", "input tax" and the "tax fraction" (r/(100 + r) — 15.5/115.5 at the standard rate of 15.5% in force from 1 January 2026 under the Finance Act, 2025 (Act No. 7 of 2025); 15% applied from 1 January 2023 to 31 December 2025).

Around that core sit the specialised clusters. The money and exclusion cluster ("money", "cheque", "currency", "debt security", "equity security", "life insurance policy" in Section 2(2)) keeps pure money flows and financial paper outside "goods" and "services" and feeds the financial-services exemption. The credit cluster ("instalment credit agreement", "cash value", "motor dealer") isolates finance charges from the taxable value of hire-purchase and financial-lease supplies. The property cluster ("fixed property", "commercial rental establishment", "residential rental establishment", "returnable container", "second-hand goods", "capital goods") drives the accommodation and second-hand-goods rules. The relationship cluster — above all "connected persons" (near relatives, trusts and beneficiaries, partnerships and members, companies with 5% or more common interests, separately registered branches) — powers the anti-avoidance value rules. The cross-border cluster ("imported services", "electronic commerce operator", "resident of Zimbabwe" with its deeming proviso — G (Pvt) Ltd v ZIMRA 22-HH-011) defines the reach of the reverse charge and the digital rules. The compliance cluster ("tax invoice" — a fiscal tax invoice printed by a fiscalised device since 1 January 2022, "fiscalised electronic register", "tax period", "entertainment", "business day") underpins documentation and input-tax denials.

Finally, Section 3 supplies the Act's valuation yardstick: the open market value (OMV) of a supply is "the consideration in money which the supply … would generally fetch if supplied in similar circumstances at that date in Zimbabwe, being a supply freely offered and made between persons who are not connected persons" (Section 3(2)). The section builds a three-step cascade — actual market evidence (Section 3(2)), a "similar supply" comparison (Section 3(4)), and failing both a Commissioner-approved method (Section 3(5)) — and provides that OMV includes the VAT (Section 3(1)(b)) and that non-money consideration is valued the same way (Section 3(3)). R (Pvt) Ltd v ZIMRA 19-HH-792 and ZS (Pvt) Ltd v ZIMRA 20-FAC-113 are the annotated authorities. OMV is the valuation engine invoked throughout the Act — connected-person supplies (Section 9(4)), imported services (Section 13(3)), deemed supplies and barter — so Section 3 belongs in this lesson even though its applications are developed in Value of Supply.

Master these definitions once and the rest of the VAT chapter reads easily; skip them and every later lesson must be re-learned. That is why this lesson sits second in the rebuilt sequence, immediately after the charge.

Definitions as charging words

In ordinary statutes, definitions tidy up drafting. In the VAT Act they do the heavy lifting of imposition. Section 6(1)(a) is one sentence long; its entire scope — what is taxed, who must account, which activities are inside the net — is delegated to the Section 2 definitions of "supply", "goods", "services", "registered operator" and "trade". Parliament drafted the definitions expansively ("includes all forms…", "anything done or to be done", "whether or not for profit") precisely so that the charge would be broad and avoidance-resistant, and then drafted targeted exclusions inside the definitions (money; mortgage rights; employees; hobbies; exempt activities) to mark the boundaries. The practical consequence: most VAT disputes are definition disputes. Whether mining-claim rights are "goods" (MMI), whether a members' association carries on a "trade" (GTO Association), whether a booking intermediary supplies "services" (Travel agents T), whether members' payments are "consideration" (Law Society) — each case turned on Section 2, not Section 6.

How Section 2 is built

Section 2(1) contains the main alphabetical dictionary — over eighty entries as amended through the Finance Acts. Section 2(2) adds a sub-dictionary of financial terms ("cheque", "currency", "debt security", "equity security", "life insurance policy") used within the financial-services concepts. Two reading rules matter:

1. A defined term means its definition wherever it appears in the Act, unless the context clearly requires otherwise. When Section 7(4) speaks of a "lay-by agreement" being "deemed not a supply", the word "supply" carries its full Section 2 breadth.
2. Definitions cross-refer: "taxable supply" depends on Section 6(1)(a) and Section 10; "exempt supply" on Section 11; "registered operator" on Sections 23 and 53; "open market value" on Section 3; "connected persons" reaches into the Income Tax Act's "near relative". A definition is only fully understood with its cross-references resolved — which this lesson does.

Where this lesson sits

The preceding lesson (Imposition and Scope of VAT) walked the charge (Section 6) and the deemed supplies (Section 7), using the definitions as needed. This lesson reverses the lens: the definitions take centre stage, organised into functional clusters, each tied to the provisions it powers — so that in the lessons that follow (registration, time, value, imports, documentation) every defined term is already familiar. Section 3 (open market value) completes the interpretive toolkit because it is itself a definition-support provision: it tells the reader how to compute the "open market value" the definitions and value rules invoke.

B.1 Section 2(1) — the principal dictionary

The framework provisions are: Section 2(1) ("In this Act—" followed by the alphabetical definitions); Section 2(2) (definitions of "cheque", "currency", "debt security", "equity security" and "life insurance policy" "for the purposes of subsection (1)"); and Section 3 (Determination of "open market value"). The administration provisions that follow — Section 4 (Act administered by the Commissioner) and Section 5 (delegation of the Commissioner's functions to ZIMRA officers, revocable, with delegated acts deemed the Commissioner's until set aside) — give the institutional context: "Commissioner" and "Authority" (the Zimbabwe Revenue Authority established by Section 3 of the Revenue Authority Act [Chapter 23:11]) appear throughout the dictionary.

Amendment history is woven into the definitions and matters for old-vs-new analysis. Among the changes visible in the 27 May 2025 source: "imported services" was substituted by the Finance Act 1 of 2019 (w.e.f. 1 January 2019); "electronic commerce operator" was inserted by the Finance Act 8 of 2022 (gazetted 24 October 2022); "tax invoice" was substituted by Act 4 of 2012 and again by the Finance Act 7 of 2021 (w.e.f. 1 January 2022) to mean a fiscal tax invoice; "fiscalised electronic register" was substituted by the Finance (No. 2) Act 8 of 2014; the old "domestic goods and services" definition was repealed in 2014 and "motor vehicle" in 2005; "clearing agent" and "short term insurance" were inserted by the Finance Act 8 of 2015; and the references to the Private Business Corporations Act were overtaken by the Companies and Other Business Entities Act [Chapter 24:31] from 13 February 2020 (editorial notes in the source).

B.2 Section 3 — determination of "open market value"

Section 3 is short but architecturally important:

• Section 3(1)(a) defines "similar supply": another supply that, "in respect of the characteristics, quality, quantity, functional components, materials and reputation" of the goods or services, is the same as or closely or substantially resembles the supply being valued.
• Section 3(1)(b): the open market value of a supply includes any tax charged under Section 6(1)(a) on it — OMV is a tax-inclusive figure, so extracting the VAT from an OMV requires the tax fraction (15.5/115.5).
• Section 3(2) — the primary rule: OMV is "the consideration in money which the supply … would generally fetch if supplied in similar circumstances at that date in Zimbabwe, being a supply freely offered and made between persons who are not connected persons". Note the four anchors: money measure; date-specific; Zimbabwean market; unconnected parties (the arm's-length idea). R (Pvt) Ltd v ZIMRA 19-HH-792 is annotated here.
• Section 3(3): the OMV of consideration that is not money (the goods received in a barter, for instance) is ascertained "in the same manner, with any necessary modifications" — also annotated with R (Pvt) Ltd.
• Section 3(4) — first fallback: where Section 3(2) cannot be applied (no market for the actual supply), OMV is what a "similar supply" would generally fetch in similar circumstances between unconnected persons. ZS (Pvt) Ltd v ZIMRA 20-FAC-113 is the annotated authority.
• Section 3(5) — final fallback: where neither (2) nor (4) yields a value, OMV is determined by "a method approved by the Commissioner which provides a sufficiently objective approximation" of the money consideration obtainable.

The cascade is mandatory in order: actual-market evidence first, similar-supply comparables second, constructed approximation last. The provisions that invoke OMV — Section 9(4) connected-person supplies where the recipient cannot fully deduct, Section 13(3) imported services (greater of consideration and OMV), the deemed-supply valuations, and the anti-avoidance reconstruction in Section 77 — are treated in Value of Supply and Valuation Rules, VAT on Imports and Exports and VAT Anti-Avoidance Rules and ZIMRA Powers.

B.3 The rate context

Definitions interact with the rate: the "tax fraction" is defined by formula (r/(100 + r), r being the Section 6(1) rate), so it floats automatically with the Charging Act. As established in Imposition and Scope of VAT: 15% applied from 1 January 2023 (Finance (No. 2) Act 10 of 2022, the rate in the 27 May 2025 source consolidation); the Finance Act, 2025 (Act No. 7 of 2025) raised the standard rate to 15.5% w.e.f. 1 January 2026 (ZIMRA rate-change notice; Public Notice 07 of 2026), making the current tax fraction 15.5/115.5. All computations in this lesson use 15.5%.

C.1 The charge cluster — the words inside Section 6(1)(a)

"Supply" — "includes all forms of supply, irrespective of where the supply is effected, and any derivative of 'supply' shall be construed accordingly". Three features: (i) inclusive, not exhaustive — sale, barter, exchange, lease, cession, donation, expropriation all qualify; (ii) non-territorial — territoriality enters through "trade" and the export rules, not through "supply"; (iii) derivative-extending — "supplier", "supplied", "supplying" all carry the same breadth. The annotation records Mylo (Pvt) Ltd v ZIMRA 16-HH-717: a transaction "to fulfil any want or any deficiency suffered by a third party, as in a barter transaction" is a supply. "Supplier" is the person supplying; "recipient" the person to whom the supply is made — the pair that anchors invoicing, input-tax entitlement and the agency rules (Section 56). "Sale" means an agreement of purchase and sale and "any transaction or act whereby or in consequence of which ownership of goods passes or is to pass" — wider than the common-law contract of sale.

"Goods" — "corporeal movable things, fixed property and any real right in any such thing or fixed property", excluding (a) money, (b) any right under a mortgage bond or pledge of such thing or property, and (c) State-issued revenue stamps, forms or cards (except when later dealt in as collectors' pieces or investment articles). Three teaching points: (i) "corporeal" = tangible; incorporeal rights are generally services, except real rights in corporeals and fixed property, which stay in "goods" — hence MMI (Pvt) Ltd v ZIMRA 19-HH-700 treating rights to mining claims and mining sites as goods; (ii) money's exclusion means paying a price is not itself a supply (no VAT on the money leg of any transaction); (iii) the mortgage/pledge exclusion keeps security rights — created, ceded or released in lending — out of "goods" (they fall to be analysed as financial services instead).

"Fixed property" — land other than farm land, with improvements affixed; shares or units in a company conferring rights to or interests in the use of immovable property (share-block interests); time-sharing interests; and real rights in any of these. The definition explains why share-block and time-share dealings are goods transactions, and connects to the deemed-supply rules for share-block loan obligations (Section 7(15)–(16), Imposition and Scope of VAT).

"Services" — "anything done or to be done, including the granting, assignment, cession or surrender of any right or the making available of any facility or advantage", excluding goods, money and the paragraph (c) stamps. The residual category: whatever has value and is not goods or money is a service — including negative conduct (forbearance, restraint) and intermediation (Travel agents T (Pvt) Ltd v ZIMRA 15-HH-285: agents buying tickets for passengers through a central reservation system rendered "a vatable service").

"Trade" — fully dissected in Imposition and Scope of VAT; recalled here in definition-cluster terms: paragraph (a) (continuous/regular activity, in or partly in Zimbabwe, supplies for consideration, whether or not for profit, including associations and clubs — GTO Association 19-HH-464; E.J (Pvt) Ltd 19-HH-528; A.T. International 15-HH-823); paragraph (b) (notified public-authority supplies; private voluntary organisations); paragraph (c) (local authorities: water, sewage/garbage, incidental supplies, self-funding competitive business); provisos I–V (termination-is-trade — TG 19-HH-578; foreign branches out; employees out; hobbies out; exempt activities deemed non-trade).

"Registered operator" — "any person who is or is required to be registered under this Act", deemed registered from any date the Commissioner determines under Section 23 or Section 53. The "required to be" limb makes liability self-executing on crossing the Section 23 threshold (VAT Registration Requirements (ZIMRA)). "Person" includes public authorities, local authorities, companies, bodies of persons corporate or unincorporated, deceased and insolvent estates, and trust funds — the widest "person" definition in the tax statutes, matched by the representation machinery in Sections 47–56.

"Consideration" — "any payment made or to be made, including any deposit on any returnable container and tax, whether in money or otherwise, or any act or forbearance, whether or not voluntary, in respect of, in response to, or for the inducement of, the supply of any goods or services, whether by that person or by any other person", excluding "any payment made by any person as an unconditional gift to any association not for gain". The proviso: a deposit (other than on a returnable container), refundable or not, is not consideration "unless and until the supplier applies the deposit as consideration for the supply or such deposit is forfeited". Unpacking: (i) consideration is tax-inclusive by definition — the statutory basis for treating quoted prices as VAT-inclusive and applying the tax fraction; (ii) third-party payments count (donor pays the school; insurer pays the panel beater); (iii) barter counts ("or otherwise"); (iv) acts and forbearances count (a restraint accepted in exchange for goods is consideration); (v) the deposit proviso is a timing shield for security deposits — they enter the VAT base only on application or forfeiture; (vi) the unconditional-gift exclusion is the only true shelter for donative receipts, and it requires no identifiable direct valuable benefit to the payer or a connected person ("unconditional gift" is itself defined, and excludes payments by public or local authorities). Law Society of Zimbabwe v ZIMRA 18-HH-409 is the annotated authority on the boundary. "Consideration in money" includes consideration "expressed as an amount of money".

"Taxable supply" — "any supply of goods or services which is chargeable with tax under paragraph (a) of subsection (1) of section six, including tax chargeable at the rate of zero % under section ten". The definition settles the doctrinal point developed in VAT Rates and Types of Supplies: a zero-rated supply is a taxable supply — inside the system, counting toward the registration threshold, carrying full input-tax recovery — while an "exempt supply" ("a supply that is exempt from tax under section eleven", annotated with GTO Association on water) is outside the charge entirely (and, via trade proviso V, outside "trade").

"Output tax" — the tax charged under Section 6(1)(a) on the operator's own supplies. "Input tax" — tax charged under Section 6 and payable by (i) a supplier on supplies to the registered operator, (ii) the operator on its own importations, or (iii) the operator on imported services — to the extent the goods or services are acquired for consumption, use or supply in the course of making taxable supplies (the "purpose" limb and the deemed/notional input for second-hand goods are dissected in Input Tax Deep Dive (Capital Goods & Pre-Reg)). "Tax" means any tax imposed by the Act; "tax fraction" the formula r/(100 + r); "tax period" the operator's Section 27 period (Returns, Payments, Interest and Penalties); "fixed date" the commencement date (1 January 2004, fixed under Section 1(2) by SI 284/2003); "Charging Act" the Finance Act [Chapter 23:04] or other rate-fixing enactment; "repealed Act" the Sales Tax Act [Chapter 23:08] that VAT replaced.

"Invoice" vs "tax invoice" — a deliberately sharp pair. An "invoice" is merely "a document notifying an obligation to make payment" — any commercial bill, relevant to the time of supply (Section 8: issuing an invoice can trigger the supply). A "tax invoice" is "a fiscal tax invoice provided by a registered operator, and printed by a fiscalised electronic register or fiscal memory device" for Section 20 purposes — the only document that unlocks input tax (substituted by FA 7/2021 w.e.f. 1 January 2022; Documentation and Record-Keeping). A "fiscalised electronic register" is "an electronic sales register having such features as may be prescribed" (FDMS devices). Conflating "invoice" and "tax invoice" is a classic examination trap: any invoice can time a supply; only a fiscal tax invoice can evidence a deduction.

C.2 The money and financial cluster

"Money" — (a) current coins and banknotes issued by the Reserve Bank of Zimbabwe (not demonetised); (b) foreign coin or banknotes used or circulated as currency (excluding coins made wholly or mainly of precious metal), and bills of exchange, promissory notes, bank drafts, postal orders and money orders — except any of these disposed of or imported as a collector's piece, investment article or item of numismatic interest. The collector's-piece carve-out converts money-as-curiosity back into "goods": selling a demonetised note collection is a supply of goods; spending a current note is not a supply at all.

Section 2(2) sub-definitions (for the financial-services concepts): "cheque" (cheques, postal orders, money orders, traveller's cheques, and any written or electronic order to a financial institution to credit or debit an account); "currency" (banknotes or other currency of any country, except collectors' pieces or items used otherwise than as a medium of exchange); "debt security" (any interest in or right to be paid money owing — but not a cheque); "equity security" (any interest in or right to a share in the capital of a juristic person, including a member's interest in a private business corporation); "life insurance policy" (a policy issued in the ordinary course of life-insurance business under the Insurance Act [Chapter 24:07]). These feed the exempt financial services category (Section 11, VAT Rates and Types of Supplies): dealings in debt and equity securities, cheques and currency are the paradigm exempt financial supplies. "Insurance" generally (insurance or guarantee against loss, damage, injury or risk, including reinsurance — but nothing in the definition applies to insurance within "financial services"), and "short term insurance" (any insurance other than life insurance, inserted FA 8/2015) mark the line between taxable short-term cover and exempt life business — and short-term indemnity payouts trigger the Section 7(7) deemed supply (Imposition and Scope of VAT). "Precious metal" — gold, silver, platinum, iridium and other platinum-group metals, plus Minister-notified metals — supports the zero-rating and exclusion rules for monetary metals.

C.3 The credit and instalment cluster

"Instalment credit agreement" — the Act's hire-purchase/financial-lease definition, with two limbs. Limb (a) — sale: corporeal movable goods (or machinery/plant, movable or immovable) sold where (i) payment is at a future date or by instalments; (ii) the sum payable includes finance charges stipulated in the agreement; (iii) the aggregate payable exceeds the cash value; and (iv) either ownership does not pass on mere delivery/use, or the seller may repossess on default. Limb (b) — lease: rent payable periodically, including stipulated finance charges, aggregating more than the cash value, where the lessee accepts the full risk of destruction or loss and assumes insurance, maintenance and repair obligations (the financial lease). "Cash value" — for a banker or financier, the cost of the goods (with erection/installation costs) plus the Section 6(1)(a) tax; for a dealer, the normal tax-inclusive cash selling price (plus financed installation charges). The pair's purpose: under the value and time rules (Sections 8–9), an instalment credit supply is taxed once, up front, on the cash value — the finance charges escape VAT (they are exempt financial services), and the supply of the use of goods under such an agreement is deemed a supply of goods (Section 7(10)). "Motor dealer" (inserted FA 10/2003) — a registered operator regularly making taxable supplies of motor vehicles, including solely under instalment credit or economic rental agreements; the old standalone "motor vehicle" definition was repealed by Act 8 of 2005. "Rental agreement" captures the ordinary operating lease (periodic hire that is not an instalment credit agreement and not a pre-fixed-date "financial lease" under the repealed Sales Tax Act) — taxed period by period on each rental, in contrast to the up-front cash-value treatment.

C.4 The property and goods-handling cluster

"Commercial rental establishment" — (a) hotels, motels, inns, boarding houses, hostels and similar establishments where lodging is regularly provided to 5 or more persons at a periodic charge; (b) regularly or systematically let houses, flats, apartments or rooms offered as residential accommodation for continuous periods not exceeding 45 days per occupant, where annual receipts exceed (or are expected to exceed) the prescribed amount; (and a related paragraph (c) category) — the gateway to the taxable-accommodation rules, contrasted with exempt long-term residential letting (Section 11, VAT Rates and Types of Supplies). "Residential rental establishment" — a commercial rental establishment in which not less than 70% of the persons supplied with domestic goods and services reside (or are expected to reside) for 45 days or longer — the hybrid category attracting the reduced-value accommodation rule in Section 9 (Value of Supply and Valuation Rules). (The old standalone "domestic goods and services" definition was repealed by the Finance (No. 2) Act 8 of 2014; the concept survives within these definitions.)

"Returnable container" — a container whose ownership is not transferred with the contents and for which a specifically identified deposit is charged on the supplier's express undertaking to refund or credit it on return. Read with "consideration" (which includes deposits on returnable containers, unlike other deposits): the bottle deposit is part of the taxable consideration when charged, and the refund unwinds it — keeping the crate-and-bottle economy inside the net symmetrically.

"Second-hand goods" — goods "previously owned and used", excluding animals and certain gold coins (those contemplated by Section 10's zero-rating). The definition powers the notional input tax regime for acquisitions of used goods from non-registered persons and the special record-keeping duties (Section 20(7); Input Tax Deep Dive (Capital Goods & Pre-Reg), Documentation and Record-Keeping).

"Capital goods" — any asset (or component) "of a character subject to a deduction" under paragraphs (c) and (f) of Section 15(2) of the Taxes Act (the Income Tax Act's capital-allowance provisions) — the bridge definition used by the import-VAT deferment rules for capital equipment (Section 12A, VAT on Imports and Exports).

C.5 The relationship cluster — "connected persons" and the non-profit terms

"Connected persons" is the Act's relatedness web, and the trigger for the OMV substitution rule in Section 9(4) and the arm's-length stance of Section 3. Its paragraphs:

• (a) a natural person (or his deceased/insolvent estate) and any near relative (as defined in Section 2 of the Taxes Act, i.e. the Income Tax Act) or the relative's estate, or any trust fund in which such a relative is or may be a beneficiary;
• (b) a trust fund and any person who is or may be a beneficiary of it;
• (c) a partnership or registered private business corporation and any member, plus any person connected to a member;
• (d) a company and (i) any person (with spouse, minor child, or their trust funds) interested — separately or in aggregate — in 5% or more of the paid-up capital, equity share capital or voting rights, directly or indirectly; (ii) any other company with mainly the same shareholders or under the same control; (iii) any person connected to those persons or companies;
• (e) separately registered branches, divisions or trades of one registered operator (Section 51) — connected to each other;
• (f) separately deemed branches of an association not for gain (Section 23(5));
• (g) a person and a superannuation scheme whose members are mainly that person's employees or office holders.

Note how low the company threshold is — 5%, far below control — and how the web propagates (connected-to-connected). The design intent: wherever pricing between related parties could shift value out of the net, the value rules can substitute OMV; the definition casts the relatedness net wide so the substitution power is hard to structure around (Value of Supply and Valuation Rules, VAT Anti-Avoidance Rules and ZIMRA Powers).

"Association not for gain" — (a) any religious institution of a public character; or (b) any other society, association, organisation or educational institution of a public character which (i) is carried on otherwise than for profit or gain to any proprietor, member or shareholder, and (ii) is constitutionally required to apply its property and income solely to its aims, prohibited from distributing to any person (beyond good-faith reasonable remuneration for services), and obliged on winding-up to pass residual assets to a similar body. The annotation cites GTO Association 19-HH-464. The definition matters twice: only payments to an association not for gain can be excluded "unconditional gifts"; and the association's own status does not exempt its supplies — if it supplies for consideration regularly, it trades (the GTO lesson). "Unconditional gift" — a voluntary payment to such an association for its purposes, with no identifiable direct valuable benefit to the payer or a connected person, excluding payments by public or local authorities. "Employee organisation" (trade unions and similar) and "trust fund" (cash or assets administered by a fiduciary under a deed, agreement or will) complete the cluster.

"Local authority" — rural district, municipal and town councils; bodies with similar functions that may levy rates or receive approved service payments; and catchment/sub-catchment councils under the Water Act [Chapter 20:24]. The definition pairs with paragraph (c) of "trade" (which confines a local authority's trade) and with "public authority" (the State-side entities, whose supplies enter "trade" only on Ministerial notification under paragraph (b)). "Minister" — the Minister of Finance (administration assigned by SI 197/2023); "Authority" — ZIMRA; "Commissioner" — the administering Commissioner under the Revenue Authority Act (Sections 4–5 of the VAT Act).

C.6 The cross-border and digital cluster

"Imported services" — "a supply of services … made by a supplier who is not resident in Zimbabwe or carries on business outside Zimbabwe to a recipient who is a resident of Zimbabwe to the extent that such services are utilised or consumed in Zimbabwe" (substituted FA 1/2019). The three-part test (foreign supplier; resident recipient; Zimbabwean utilisation) marks the reverse-charge perimeter (Section 6(1)(c), Section 13; VAT on Imports and Exports); the "to the extent" wording makes apportionment intrinsic — only the locally consumed slice is taxed.

"Resident of Zimbabwe" — a person (other than a company) ordinarily resident in Zimbabwe, or a company incorporated in Zimbabwe; provided that any other person or company is deemed resident to the extent that it carries on any trade or other activity in Zimbabwe and has a fixed or permanent place in Zimbabwe relating to it. Note the contrasts with income tax (Tax Residence and Source of Income): VAT uses incorporation for companies (income tax uses central management and control), and the proviso adds a PE-like deeming — annotated with G (Pvt) Ltd v ZIMRA 22-HH-011 ("foreign organisations deemed to be resident"). The deeming cuts both ways: a foreign entity with a fixed Zimbabwean operation can be a "resident" recipient (reverse charge) or supplier.

"Electronic commerce operator" (inserted FA 8/2022, w.e.f. 24 October 2022) — "an operator selling, providing or delivering services from outside Zimbabwe by the use of a telecommunications network or electronic means (and whether mediated by computers, mobile telephones or other devices) to customers or users in Zimbabwe" — the trigger term for the Section 13A supplier-side digital deeming (Digital VAT, Fiscalisation and Technology). "Ancillary transport services" (cargo inspection, customs-documentation preparation, storage of transported goods) and "foreign-going aircraft" (aircraft transporting passengers or goods for reward wholly or mainly between Zimbabwean and foreign airports, or between foreign airports) feed the Section 10 zero-ratings for international transport. "Clearing agent" (inserted FA 8/2015) — a person licensed (or required to be) under Section 216A of the Customs and Excise Act — connects VAT's import machinery to Customs licensing. "Export country" and "exported" are treated in VAT on Imports and Exports with the zero-rating rules they serve.

C.7 The compliance and miscellany cluster

"Entertainment" — "the provision of any food, beverages, accommodation, entertainment, amusement, recreation or hospitality of any kind by a registered operator whether directly or indirectly to anyone in connection with a trade" — the definition behind the entertainment input-tax denial (Section 16(2); Input Tax Deep Dive (Capital Goods & Pre-Reg)), mirroring the income-tax hospitality battles (SZ 20-HH-142; IAB 22-HH-032 in the ITC stream). "Business day" — any day other than Saturday, Sunday or a public holiday (deadline arithmetic). "Tax period" — the Section 27 category period. "Returnable container", "second-hand goods", "tax invoice", "fiscalised electronic register" — covered above with their clusters. "Reserve Bank", "Revenue Act" (the Revenue Authority Act [Chapter 23:11]), "Customs Act" (Customs and Excise Act [Chapter 23:02]), "Taxes Act" (the Income Tax Act [Chapter 23:06]) and "Stamp Act" (Stamp Duties Act [Chapter 23:09]) are the cross-statute pointers — the VAT Act leans on the Taxes Act for "near relative", remuneration (trade proviso III) and capital-allowance character ("capital goods"), and on the Customs Act for the whole import machinery.

C.8 Section 3 in operation: the OMV cascade

Working the cascade on a concrete problem. Suppose a registered operator sells a specialised industrial kiln to a connected company (its 40% shareholder's other company — paragraph (d)(ii)) for USD 11,550, and ZIMRA invokes the value rules to substitute OMV:

1. Section 3(2) — actual market: is there evidence of what this kiln would generally fetch in Zimbabwe on that date between unconnected persons, freely offered? Recent sales of the same model by the operator to third parties at USD 23,100 (tax-inclusive) would settle it: OMV = USD 23,100 (tax-inclusive per Section 3(1)(b)).
2. Section 3(4) — similar supply: if the kiln is unique, value a "similar supply" — same characteristics, quality, quantity, functional components, materials and reputation, or closely/substantially resembling it (ZS (Pvt) Ltd 20-FAC-113 turned on this comparator exercise).
3. Section 3(5) — approved method: failing both, the Commissioner approves an objective approximation method (e.g. depreciated replacement cost or an income approach).

Whichever step yields the value, the tax inside it is extracted with the tax fraction: 23,100 × 15.5/115.5 = USD 3,100. And under Section 3(3) the same cascade values non-money consideration: in a barter, the consideration received (the goods taken in exchange) is valued at its OMV — R (Pvt) Ltd v ZIMRA 19-HH-792, where a non-sale disposal had to be valued as if sold at market.

All computations use the 15.5% rate (Finance Act, 2025) and tax fraction 15.5/115.5.

D.1 Individuals

Scenario 1 — deposit or consideration? Rumbidzai lets out her cottage short-term (a registered operator via her property business). A guest pays USD 462 rent plus a USD 100 security deposit. Under the consideration proviso, the deposit is not consideration when received. Output tax on receipt = 462 × 15.5/115.5 = USD 62. Three weeks later the guest breaks a window and Rumbidzai applies USD 50 of the deposit: at that moment USD 50 becomes consideration — further output tax = 50 × 15.5/115.5 = USD 6.71. The unapplied USD 50 refunded to the guest never enters the VAT base. Had the USD 100 instead been a deposit on returnable containers (say crates in a beverages trade), it would have been consideration immediately on receipt.

Scenario 2 — collector's currency. Tonderai, a registered coin dealer, sells (i) a current US$100 banknote in a forex transaction and (ii) a demonetised Rhodesian note to a collector for USD 231. Leg (i) is a dealing in "money"/"currency" — no supply of goods (exempt financial-services analysis applies to any margin). Leg (ii) is a collector's piece — excluded from "money", so it is goods: output tax = 231 × 15.5/115.5 = USD 31.

D.2 SMEs and partnerships

Scenario 3 — instalment credit agreement vs operating rental. Mutare Motors (a motor dealer) supplies a delivery van under a 36-month agreement: cash price (tax-inclusive) USD 12,705; total payable including stipulated finance charges USD 14,500; ownership passes only on final payment. Test the definition: corporeal movable goods ✔; instalments ✔; stipulated finance charges ✔; aggregate (14,500) exceeds cash value (12,705) ✔; ownership withheld ✔ — an instalment credit agreement. Consequences: the supply is a supply of goods (Section 7(10)); it is taxed up front on the cash value: output tax = 12,705 × 15.5/115.5 = USD 1,705; and the USD 1,795 of finance charges are never subject to VAT (exempt finance). If instead the van were hired month-to-month with the lessor bearing insurance and maintenance and no path to ownership, it would be an ordinary rental agreement: each month's rental is taxed as it falls due — say rent of USD 577.50/month → output tax 577.50 × 15.5/115.5 = USD 77.50 per month.

Scenario 4 — connected persons and the 5% trap. Chenai owns 6% of Kombi Spares (Pvt) Ltd. The company sells her husband a vehicle hoist (OMV USD 4,620 tax-inclusive) for USD 1,155. Chenai's spouse is within paragraph (d)(i) (spouse of a ≥5% holder — and her husband is also her "near relative"-linked connected person under (a)). Because the recipient (a private individual) cannot deduct input tax, the value rules substitute OMV: output tax = 4,620 × 15.5/115.5 = USD 620, not 1,155 × 15.5/115.5 = USD 155. The 5% threshold surprises SME shareholders who assume "connected" means "controlled".

Scenario 5 — the sports club and the gift that wasn't. A community football association (constitutionally non-distributing, public character — an association not for gain) receives: (i) USD 5,000 from a member who gets premium seating and branding at matches; (ii) USD 5,000 from a well-wisher who receives nothing. Receipt (ii) is an unconditional gift — excluded from consideration, no supply. Receipt (i) buys identifiable direct benefits — it is consideration for supplies in the course of the association's trade (GTO Association; Law Society): output tax = 5,000 × 15.5/115.5 = USD 671.00 (rounded), and the receipts count toward the registration threshold.

D.3 Large corporates and multinationals

Scenario 6 — deemed resident via fixed place. A Mauritius-incorporated logistics group runs a permanent depot in Harare. Under the "resident of Zimbabwe" proviso it is deemed resident to the extent of that Zimbabwean activity (G (Pvt) Ltd 22-HH-011). When the depot procures management services from the group's Johannesburg head office for the Zimbabwean operation (fee USD 120,000, consumed in Zimbabwe), the depot is a resident recipient of imported services: reverse-charge output tax = 120,000 × 15.5% = USD 18,600 (recoverable as input tax only to the extent of taxable use — VAT on Imports and Exports).

Scenario 7 — OMV cascade on a group transfer. Conglomerate A transfers a custom bottling line to its 100%-owned subsidiary (connected persons, para (d)(ii)) for a book-value USD 50,000 when no identical machine trades locally. Section 3(2) fails (no market in the actual asset); Section 3(4): a similar supply — a comparable European line of like capacity, quality and reputation landed in Zimbabwe — would fetch USD 462,000 tax-inclusive; OMV = USD 462,000; output tax = 462,000 × 15.5/115.5 = USD 62,000. Documentation of the comparator (characteristics, quality, quantity, functional components, materials, reputation — the Section 3(1)(a) checklist) is what survives audit (ZS (Pvt) Ltd 20-FAC-113).

Scenario 8 — entertainment definition at audit. A bank's hospitality suite at a stadium, staff year-end party and client cocktail evenings all fall within "entertainment" ("hospitality of any kind … directly or indirectly to anyone in connection with a trade"); the input tax on those costs is denied under Section 16(2) regardless of the marketing rationale — a recurring large-corporate audit adjustment (Input Tax Deep Dive (Capital Goods & Pre-Reg)).

• Mylo (Pvt) Ltd v ZIMRA 16-HH-717 — "supply"/Section 6(1)(a): barter ("to fulfil any want or any deficiency suffered by a third party") is a supply; form irrelevant, money unnecessary.
• MMI (Pvt) Ltd v The Commissioner-General, ZIMRA 19-HH-700 — "goods": rights to mining claims and mining sites are goods ("personal or real right"); their disposal is chargeable.
• TG v ZIMRA 19-HH-578 — "goods"/trade proviso I/Section 7(14): the assets of a defunct carpet factory sold by the liquidator were goods supplied in the course of (terminating) trade.
• Travel agents T (Pvt) Ltd v ZIMRA 15-HH-285 — "services": intermediary booking activity through a central reservation system is "a vatable service".
• GTO Association v The Commissioner-General of ZIMRA 19-HH-464 — "trade", "association not for gain", "exempt supply" (water): a members' association supplying for consideration trades, "whether or not for profit"; non-profit constitution does not take supplies out of the net.
• E.J (Pvt) Ltd v ZIMRA 19-HH-528 — "trade": renting and disposing of properties is a continuing trade; disposals taxable.
• A.T. International Ltd v ZIMRA 15-HH-823 — "trade"/Section 6: attribution of supplies and importations in agency settings.
• Law Society of Zimbabwe v ZIMRA 18-HH-409 — "consideration": the boundary between members' payments that buy supplies and excluded unconditional gifts/regulatory receipts.
• G (Pvt) Ltd v ZIMRA 22-HH-011 — "resident of Zimbabwe": foreign organisations deemed resident to the extent of a Zimbabwean trade with a fixed or permanent place (the case is also authority on the cumulative conditions of Section 10(2)(l) zero-rating — VAT on Imports and Exports).
• R (Pvt) Ltd v ZIMRA 19-HH-792 — Section 3(2)–(3): open market value governs non-sale disposals and non-money consideration; the High Court applied the deemed-sale-at-market logic (also met in the CGT stream).
• ZS (Pvt) Ltd v ZIMRA 20-FAC-113 — Section 3(4): the Fiscal Appeal Court on valuing by "similar supply" comparators where no market exists for the actual supply (also the pooling authority for Section 54 — Special VAT Rules and Industry Provisions).
• Delta Beverages (Pvt) Ltd v ZIMRA 23-HH-577 — the chapeau words of Section 6(1) and "tax": Section 6 imposes "a tax"; the currency of payment is a Section 38 question (Returns, Payments, Interest and Penalties).

Where a definition has no annotated case (e.g. "instalment credit agreement", "connected persons", "returnable container"), the statements above rest on the statutory text in the 27 May 2025 source — the provisions operate mechanically and have generated administrative rather than reported judicial dispute.

1. Reading Section 6 without Section 2. Practitioners argue "it wasn't a sale, so no VAT" — but "supply" includes all forms; "sale" itself extends to any ownership-passing transaction; barter and forbearance are consideration. Always test the defined meaning, not the everyday one.
2. Conflating "invoice" with "tax invoice". Any payment-notifying document can trigger the Section 8 time of supply; only a fiscal tax invoice (printed by a fiscalised device, post-FA 7/2021) supports an input-tax deduction. Operators who treat supplier statements or pro-formas as deduction documents lose the input tax (and the Section 20 rules limit one tax invoice per supply).
3. Treating zero-rated and exempt as synonyms. "Taxable supply" includes zero-rated supplies; "exempt supply" is outside the charge and (via trade proviso V) outside "trade". The difference decides registration liability, input-tax recovery and apportionment (VAT Rates and Types of Supplies, Input Tax Deep Dive (Capital Goods & Pre-Reg)).
4. Missing the deposit proviso — in both directions. Security deposits are not consideration until applied or forfeited (don't pay VAT early); returnable-container deposits are consideration immediately (don't pay VAT late).
5. Assuming "connected" means "controlled". The company limb of "connected persons" bites at 5% of capital, equity or votes — aggregated with spouse, minor children and their trusts, and propagating through common-shareholder companies. Price a related-party deal at undervalue and the OMV substitution follows.
6. Forgetting OMV is tax-inclusive. Section 3(1)(b) builds the VAT into the open market value; computing output tax as OMV × 15.5% (instead of OMV × 15.5/115.5) overstates the tax.
7. Charging VAT on finance charges. In a properly documented instalment credit agreement the stipulated finance charges sit outside the cash value and outside VAT. Conversely, failing to stipulate the finance charges in the agreement collapses the whole receivable into taxable consideration — a drafting error with a 15.5% price.
8. Non-profits relying on their constitution instead of their receipts. "Association not for gain" status only shelters unconditional gifts; subscriptions and fees that buy identifiable benefits are consideration for supplies (GTO Association; Law Society).
9. Treating foreign incorporation as conclusive of non-residence. The "resident of Zimbabwe" proviso deems a foreign person resident to the extent of a Zimbabwean trade with a fixed place (G (Pvt) Ltd) — switching on reverse-charge and registration consequences groups routinely miss.
10. Ignoring the Section 3 cascade order. Jumping straight to a "Commissioner-approved method" (or a self-made formula) when actual-market or similar-supply evidence exists invites substitution of the assessment; equally, ZIMRA must itself respect the order — a ground of objection where it does not (VAT Objections and Appeals).

Work through the questions one at a time. Choose an answer and it is graded immediately, with an explanation and the provision it comes from. Your progress is saved, so you can stop and resume.

• Section 2 is operative law, not a glossary: the charge in Section 6(1)(a) is built entirely from defined terms, and most VAT litigation is definition litigation (Mylo, MMI, Travel agents T, GTO Association, Law Society).
• The charge cluster: "supply" = all forms, anywhere; "goods" = corporeal movables + fixed property + real rights (excl. money, mortgage/pledge rights, revenue stamps); "services" = anything done or to be done; "registered operator" includes persons required to register; "consideration" is tax-inclusive, covers third-party payments, acts and forbearances, excludes unconditional gifts, and holds security deposits in suspense until applied or forfeited.
• "Taxable supply" includes zero-rated supplies; "exempt supply" (Section 11) is outside the charge — the single most consequential pairing in the dictionary (registration, recovery, apportionment all turn on it).
• "Invoice" ≠ "tax invoice": any payment-notifying document can fix the time of supply; only a fiscal tax invoice from a fiscalised electronic register (FA 7/2021, w.e.f. 1 Jan 2022) unlocks input tax.
• The credit cluster (instalment credit agreement + cash value) taxes hire-purchase once, up front, on the tax-inclusive cash value, leaving stipulated finance charges outside VAT; operating rentals are taxed rental by rental.
• "Connected persons" bites at 5% of capital, equity or votes (with spouse/minor-child/trust aggregation, near relatives, trusts and beneficiaries, partnerships, common-shareholder companies and separately registered branches) — the trigger for OMV substitution.
• Section 3's OMV cascade is mandatory and ordered: (2) actual market between unconnected persons → (4) "similar supply" comparator (Section 3(1)(a) checklist) → (5) Commissioner-approved objective method; OMV includes the tax (Section 3(1)(b)), and non-money consideration is valued the same way (Section 3(3)) (R (Pvt) Ltd 19-HH-792; ZS (Pvt) Ltd 20-FAC-113).
• Cross-border reach is definitional: "imported services" (foreign supplier / resident recipient / Zimbabwean consumption), "electronic commerce operator" (FA 8/2022) and the "resident of Zimbabwe" fixed-place deeming (G (Pvt) Ltd 22-HH-011) together set the perimeter of the reverse charge and the digital rules.
• Rates float through the "tax fraction" r/(100 + r): 15.5/115.5 from 1 January 2026 (Finance Act, 2025 — Act No. 7 of 2025; PN 07/2026); 15/115 for 2023–2025 supplies — always match the fraction to the Section 8 time of supply.

Table 1 — The definition clusters and the provisions they power

Cluster	Key defined terms	Provisions powered	Lesson
Charge	supply; goods; services; trade (+5 provisos); registered operator; person; consideration; taxable/exempt supply; output/input tax; tax fraction; fixed date; Charging Act	Section 6 charge; Section 7 deemed supplies; Section 10/11 rates	Imposition and Scope of VAT, VAT Rates and Types of Supplies
Money/financial	money; cheque; currency; debt/equity security; life insurance policy; insurance; short term insurance; precious metal	Section 11 financial-services exemption; Section 7(7) indemnities	VAT Rates and Types of Supplies
Credit	instalment credit agreement; cash value; rental agreement; motor dealer	Sections 8–9 timing/value of credit supplies; Section 7(9)–(10)	Time of Supply Rules, Value of Supply and Valuation Rules
Property	fixed property; commercial/residential rental establishment; returnable container; second-hand goods; capital goods	Section 9 accommodation value; notional input; Section 12A deferment	Value of Supply and Valuation Rules, Input Tax Deep Dive (Capital Goods & Pre-Reg)
Relationships	connected persons; association not for gain; unconditional gift; trust fund; local/public authority	Section 9(4) OMV substitution; Section 3; consideration exclusion	Value of Supply and Valuation Rules, VAT Anti-Avoidance Rules and ZIMRA Powers
Cross-border/digital	imported services; electronic commerce operator; resident of Zimbabwe; foreign-going aircraft; ancillary transport services; clearing agent	Section 6(1)(c)/Section 13 reverse charge; Section 13A; Section 10 transport zero-ratings	VAT on Imports and Exports, Digital VAT, Fiscalisation and Technology
Compliance	invoice; tax invoice; fiscalised electronic register; tax period; entertainment; business day	Section 8 timing; Section 20 documentation; Section 16(2) denials; Section 27 periods	Documentation and Record-Keeping, Returns, Payments, Interest and Penalties

Table 2 — Commonly confused pairs

Pair	The difference	Why it matters
Invoice vs tax invoice	Any payment-notifying document vs fiscal device-printed Section 20 document	Timing trigger vs input-tax key
Taxable (incl. zero-rated) vs exempt supply	Chargeable under Section 6(1)(a) (even at 0%) vs excluded by Section 11	Registration, input recovery, apportionment
Security deposit vs returnable-container deposit	Suspended until applied/forfeited vs consideration immediately	Timing of output tax
Instalment credit agreement vs rental agreement	Finance-charge structure, risk transfer, title retention vs simple periodic hire	Up-front tax on cash value vs tax per rental; finance charges exempt
Money vs collector's piece	Medium of exchange vs numismatic/investment article	No supply vs taxable supply of goods
Resident (incorporation/ordinary residence) vs deemed resident	Status vs fixed-place activity deeming	Reverse-charge and registration exposure (G (Pvt) Ltd)
Connected vs controlled	5% interest (with aggregation) vs majority control	OMV substitution reaches far below control

Diagram — the Section 3 open market value cascade

flowchart TD
 A[Supply must be valued at OMV
e.g. Section 9 4 connected persons, barter, deemed supply] --> B{Section 3 2: does the ACTUAL supply
trade in Zimbabwe between
unconnected persons?}
 B -->|Yes| C[OMV = price it would generally fetch
at that date, freely offered]
 B -->|No| D{Section 3 4: is there a SIMILAR supply?
Section 3 1 a checklist: characteristics, quality,
quantity, components, materials, reputation}
 D -->|Yes| E[OMV = price the similar supply
would generally fetch]
 D -->|No| F[Section 3 5: Commissioner-approved method
objective approximation]
 C --> G[OMV includes VAT - Section 3 1 b]
 E --> G
 F --> G
 G --> H[Extract tax with tax fraction
OMV x 15.5 / 115.5]

Statutes & sections

• VAT Act [Chapter 23:12] — Section 2(1) (definitions discussed: "ancillary transport services", "association not for gain", "Authority", "business day", "capital goods", "cash value", "Charging Act", "clearing agent", "commercial rental establishment", "connected persons", "consideration", "consideration in money", "electronic commerce operator" (FA 8/2022), "employee organisation", "entertainment", "exempt supply", "fiscalised electronic register" (FA (No. 2) 8/2014), "fixed date", "fixed property", "foreign-going aircraft", "goods", "imported services" (FA 1/2019), "input tax", "instalment credit agreement", "insurance", "invoice", "local authority", "Minister" (SI 197/2023 assignment), "money", "motor dealer" (FA 10/2003), "open market value", "output tax", "person", "precious metal", "recipient", "registered operator", "rental agreement", "repealed Act", "resident of Zimbabwe", "residential rental establishment", "returnable container", "sale", "second-hand goods", "services", "short term insurance" (FA 8/2015), "supplier", "supply", "tax", "tax fraction", "tax invoice" (Act 4/2012; FA 7/2021), "tax period", "taxable supply", "trade" with provisos I–V, "trust fund", "unconditional gift"); Section 2(2) ("cheque", "currency", "debt security", "equity security", "life insurance policy"); Section 3 (open market value: (1)(a) "similar supply"; (1)(b) tax-inclusive; (2) primary rule; (3) non-money consideration; (4) similar-supply fallback; (5) Commissioner-approved method); Section 4 (Commissioner administers); Section 5 (delegation); cross-referenced: Sections 6–7, 8–11, 13, 13A, 16(2), 20, 23, 27, 51, 53, 56, 77.
• Income Tax Act [Chapter 23:06] ("Taxes Act") — Section 2 "near relative" (imported by "connected persons"); Thirteenth Schedule "remuneration" (trade proviso III); Section 15(2)(c)/(f) (character test for "capital goods").
• Finance Act [Chapter 23:04], Chapter IV — rate machinery (15% per FA (No. 2) 10/2022 in the 27 May 2025 source); Finance Act, 2025 (Act No. 7 of 2025) — 15.5% w.e.f. 1 January 2026.
• Customs and Excise Act [Chapter 23:02] — Section 216A (clearing agents); Revenue Authority Act [Chapter 23:11] — Section 3 (ZIMRA); Companies and Other Business Entities Act [Chapter 24:31] (successor to the Private Business Corporations Act references, w.e.f. 13 February 2020); Reserve Bank of Zimbabwe Act [Chapter 22:15]; Insurance Act [Chapter 24:07]; Water Act [Chapter 20:24]; Sales Tax Act [Chapter 23:08] (the "repealed Act").

Case law

• Mylo (Pvt) Ltd v ZIMRA 16-HH-717 — "supply": barter/third-party-want transactions.
• MMI (Pvt) Ltd v Commissioner-General, ZIMRA 19-HH-700 — "goods": mining-claim rights.
• TG v ZIMRA 19-HH-578 — "goods"; liquidation sales within trade.
• Travel agents T (Pvt) Ltd v ZIMRA 15-HH-285 — "services": intermediation vatable.
• GTO Association v Commissioner-General, ZIMRA 19-HH-464 — "trade"; "association not for gain"; exempt supplies (water).
• E.J (Pvt) Ltd v ZIMRA 19-HH-528 — "trade": property renting/disposal.
• A.T. International Ltd v ZIMRA 15-HH-823 — "trade"/agency attribution.
• Law Society of Zimbabwe v ZIMRA 18-HH-409 — "consideration" vs unconditional gifts.
• G (Pvt) Ltd v ZIMRA 22-HH-011 — "resident of Zimbabwe": fixed-place deeming of foreign organisations.
• R (Pvt) Ltd v ZIMRA 19-HH-792 — Section 3(2)–(3): OMV for non-sale disposals and non-money consideration.
• ZS (Pvt) Ltd v ZIMRA 20-FAC-113 — Section 3(4): similar-supply valuation (Fiscal Appeal Court).
• Delta Beverages (Pvt) Ltd v ZIMRA 23-HH-577 — Section 6 chapeau; "a tax" and the Section 38 currency rules.

ZIMRA guidance

• VAT Rate Change: Implications for TaRMS Submissions and Public Notice 07 of 2026 — 15.5% rate w.e.f. 1 January 2026; tax fraction 15.5/115.5.
• Comprehensive Guide to the VAT 7 — ZIMRA External Guide (return-level use of the defined terms; see Returns, Payments, Interest and Penalties).