TAX BULLETIN Zimbabwe 2014

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TAX BULLETIN Zimbabwe 2014
TAX BULLETIN

Zimbabwe 2014
BDO TAX SERVICES

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Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                        Page   1
CONTENTS

1      INTRODUCTION............................................      3
2      RATES OF TAX: EMPLOYMENT INCOME .................             4
3      HIGHLIGHTS OF THE 2014 BUDGET .....................           6
4      TAXATION IN ZIMBABWE………………………………………….. 19
5      TAXATION OF INDIVIDUALS .............................. 19
       Benefits .................................................... 19
       Exempt income ........................................... 21
       Deductions ................................................. 21
       Prohibited Deductions………………………………………………. 22
       Credits ..................................................... 22
       Tax computation example: Individual ................. 23
6      TAXATION OF COMPANIES ................................ 24
7      CAPITAL ALLOWANCES ................................... 26
8      WITHHOLDING TAXES .................................... 29
9      PRESUMPTIVE TAXES…………………………………………………. 31
10     CAPITAL GAINS TAX....................................... 33
11     VALUE ADDED TAX ........................................ 35
12     PAYROLL TAXES ........................................... 37
13     ESTATE DUTY .............................................. 38
14     STAMP DUTY ............................................... 38
15     CUSTOMS DUTY……………………………………………………….…. 38
16     TAX RATES ................................................. 39
17     DOUBLE TAXATION AGREEMENTS ....................... 41
18     TAX RATES IN SELECTED COUNTRIES………………………. 43

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                          Page   2
1.     INTRODUCTION

       BDO Tax & Advisory Services (Private) Limited is an associate firm of BDO Zimbabwe.
       BDO Zimbabwe, a Zimbabwean partnership, is a member of BDO International
       Limited, a UK Company Limited by guarantee, and forms part of the BDO network of
       independent member firms. BDO is the brand name for the BDO network and for
       each of the BDO member firms.

       BDO Tax & Advisory Services (Pvt) Ltd is geared towards offering tax planning
       strategies and policies that minimize your tax burden and ensure the success of your
       business.

       We provide instant support in a tax crisis and help to protect you from the risk of
       non-compliance against the backdrop of intense levels of scrutiny from the tax
       authorities.

       The contents of this booklet incorporate the 2014 tax proposals and give a brief
       outline of the tax system in Zimbabwe.

       We advise our clients to seek professional advice from the firm before making any
       decision regarding the contents of this booklet.

        2014 BUDGET: - TAXATION PROPOSALS

        The 2014 budget proposals were presented on the 19th December 2013 by the
        Finance Minister, Honourable Patrick Chinamasa and the tax measures went through
        Parliament in January 2014.

        Salient features of the taxation measures in the budget are summarized below:-

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                      Page   3
2.     RATES OF TAX: EMPLOYMENT INCOME

                                        2014 ANNUAL PAYE TABLE
                                 1st January 2014 – 31st December 2014
Band of Taxable Income              Amount         Tax Rate          Tax     Cumulative Tax
          US$                        US$              %              US$         US$

        1   -    3 000                3,000           0%               -            -
    3 001   - 12 000                  9,000          20%             1,800        1,800
   12 001   - 24 000                 12,000          25%             3,000        4,800
   24 001   - 60 000                 36,000          30%            10,800       15,600
   60 001   - 90 000                 30,000          35%            10,500       26,100
   90 001   - 120 000                30,000          40%            12,000       38,100
  120 001    - 240 000              120,000          45%            54,000       92,100
  240 001     and more                               50%

            Annual Ready Reckoner Table: 1st January 2014 – 31st December 2014

Band of Taxable Income                             Tax Rate                  Cumulative Band
          US$                                         %                         Deduct
                                                                                  US$

        1   -    3 000            Multiple By         0%             Less           -
    3 001   - 12 000              Multiple By        20%             Less           600
   12 001   - 24 000              Multiple By        25%             Less         1,200
   24 001   - 60 000              Multiple By        30%             Less         2,400
   60 001   - 90 000              Multiple By        35%             Less         5,400
   90 001   - 120 000             Multiple By        40%             Less         9,900
  120 001    - 240 000            Multiple By        45%             Less        15,900
  240 001     and more                               50%             Less        27,900

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                           Page   4
Monthly Table: 1st January 2014 – 31st December 2014

Band of Taxable Income              Amount      Tax Rate          Tax        Cumulative Tax
          US$                        US$           %              US$            US$

        1   -    250                   250         0%               -               -
      251   - 1 000                    750        20%              150             150
    1 001   - 2 000                  1,000        25%              250             400
    2 001   - 5 000                  3,000        30%              900           1,300
    5 001   - 7 500                  2,500        35%              875           2,175
    7 501   - 10 000                 2,500        40%            1,000           3,175
   10 001   - 20 000                10,000        45%            4,500           7,675
   20 001    and more                             50%

            Monthly Ready Reckoner Table: 1st January 2014 – 31st December 2014

Band of Taxable Income                          Tax Rate                     Cumulative Band
          US$                                      %                            Deduct
                                                                                  US$

        1   -    250              Multiple By      0%            Less               -
      251   - 1 000               Multiple By     20%            Less               50
    1 001   - 2 000               Multiple By     25%            Less              100
    2 001   - 5 000               Multiple By     30%            Less              200
    5 001   - 7 500               Multiple By     35%            Less              450
    7 501   - 10 000              Multiple By     40%            Less              825
   10 001   - 20 000              Multiple By     45%            Less            1,325
   20 001    and more                             50%            Less            2,325

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                           Page   5
3.     HIGHLIGHTS OF THE 2014 BUDGET

       3.0     INCOME TAX

       3.1     EMPLOYMENT TAX RATES

               The individual income tax bands remain mainly unchanged except for the
               introduction of a 50% band on income exceeding US$20,000 per month.

               The marginal tax rate on employment income has therefore increased from
               46,35% to 51,5%.

               TAX FREE BONUS

               The tax free bonus threshold remains pegged at US$1,000 per annum.

               DEEMED MOTORING BENEFITS

               With effect from 1 January 2014, section 8(1)(f) of the Income Tax Act [Chapter 23:06]
               is amended by increasing the deemed motoring benefits as follows;”.

                 ENGINE CAPACITY                2013 Rate                      2014 Rate

                 Up to 1,500cc                  USD   150 per   month          USD   300 per   month
                 1,501cc to 2,000cc             USD   200 per   month          USD   400 per   month
                 2,001cc to 3,000cc             USD   300 per   month          USD   600 per   month
                 Above 3,001cc                  USD   400 per   month          USD   800 per   month

               RETRENCHMENT / SEVERANCE PACKAGES

               With effect from 1 January 2013, the non-taxable portion of a retrenchment package
               is increased to US$10,000 or one-third of the retrenchment package up to a maximum
               of US$60,000.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                                 Page   6
3.2 CORPORATE TAX MEASURES

                Tax Exemptions - Income from Mortgage Finance

               With effect from 1 January 2014, in addition to building societies, receipts by
               financial institutions attributable to mortgage finance for residential
               accommodation are exempt from income tax.

               Tax Exemption - Interest earned on loans to small scale miners

               With effect from 1 January 2014, interest accruing from loans to small scale
               gold miners is exempt from tax.

               Insurance and Pension housing fund

               With effect from 1 January 2014, receipts and accruals of the fund are exempt
               from tax.

               Tax Exemption: Investor Protection Fund

               With effect from 1 January 2013, receipts and accruals of the fund are exempt
               from tax.

               Indigenisation and Empowerment costs

               The following costs of indigenisation and empowerment are tax deductible
               with effect from 1 January 2013:-

               (i)       any contribution or donation paid by a taxpayer in the year of
                         assessment to a community share ownership trust or scheme
                         established by the taxpayer in compliance with the Indigenisation and
                         Empowerment Act [Chapter 14:33].

               (ii)      the value of shares of a corporate taxpayer that are lent in the year of
                          assessment to an indigenisation partner of the taxpayer pursuant to a
                          corporate vendor-financed loan; the deduction will be spread over the
                          tenure of the loan.

               (iii)     Loan interest payable by an indigenisation partner in the year of
                         assessment on any loan advanced to him or her to purchase shares in
                         the company of which he or she is an indigenous partner;

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                           Page   7
Prohibited Deductions: Royalties

               With effect from 1 January 2014, royalties paid during the year of assessment
               will no longer be tax deductible.

               Transfer Pricing

               With effect from 1 January 2014, new transfer pricing regulations have been
               introduced which empower the Commissioner to adjust the taxable income
               where there is income split between a taxpayer and an associate.

               Depletion Fees

               A depletion fee at a rate of between 2.5% to 5% on the “gross value of the
               proceeds of the sale of any minerals” will now be payable to the Consolidated
               Revenue Fund with effect from 1 January 2014 as opposed to the Minerals
               Marketing Corporation of Zimbabwe (MMCZ).

               “Gross value of the proceeds of the sale of minerals” means the full value of
               such proceeds before any deduction by the MMCZ, including any deduction
               that the MMCZ would have been entitled to make.

               Special dividend on sale of diamonds

               A special dividend based on 15% of the gross value of the proceeds of any sale
               of diamonds will be payable by the MMCZ to the Consolidated Revenue Fund
               within 24hours of acquaintance of export documentation to a batch of
               diamonds.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                        Page   8
3.3 VALUE ADDED TAX

               Zero-Rating of products

               White Sugar-

               In order to avail relief to manufacturers and retailers, white sugar, is now zero
               rated retrospectively with effect from 1 February 2009.

               Soya Bean Crude Oil –

               In order to alleviate the costs associated with importation of crude oil,
               thereby enhancing local refining of cooking oil, it is proposed to zero rate and
               suspend customs duty on imported soya bean crude oil.

               Local Diamond Sales

               With effect from 1st January 2014, local sales of rough diamonds are zero rated
               to encourage beneficiation/ value addition.

               VAT Deferment

               The 90 day VAT deferment facility will continue to be available for the
               importation of industrial and capital equipment by companies in the mining,
               agriculture, manufacturing, and health and aviation transport sectors.

               VAT exemption on imported electricity

               It is proposed to exempt electricity imports from VAT retrospectively with
               effect from 1 February 2009.

               Rationalisation of zero rated products

               With effect from 1 January, 2014, the following goods were removed from the
               list of zero-rated products: yoghurt, cream, butter and plain buns.

               Input Tax – Prohibited Deduction

               With effect from 1 January 2014, input tax cannot be claimed on the export of
               unbeneficiated hides, unbeneficiated platinum or raw diamonds.

               Tax Invoices

               With effect from 1 January 2014, suppliers will be penalised for failure to issue
               VAT invoices with prescribed features.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                          Page   9
Penalties for late VAT registration

               With effect from 1 January 2014, failure to register for VAT will attract a fine
               not exceeding US$30 for every day the taxpayer remains unregistered.

               Input Tax - Bill of Entry

               With effect from 1 January 2014, the time period within which a Bill of Entry
               can be used to claim input tax has been limited to twelve months.

               Objections against fiscalised electronic registers

               With effect from 1 January 2014, the VAT Act (Chapter 23:12) is amended in
               order to allow clients to lodge objections against the assessment or decisions
               made in respect of fiscal regulations.

               VAT on Exports: Minerals

               With effect from 1st January 2015, a 15% VAT on exports will be levied on
               exports of unbeneficiated platinum and rough diamonds.

               VAT on Exports

               With effect from 1st January 2014 unprocessed hides will be levied an export
               tax of $0,75 per kg.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                        Page 10
3.4      WITHHOLDING TAXES

               Royalties

               With effect from 1 January 2014, the rates of royalties for small scale miners
               of gold have been reviewed from 7% to 3%.

               Taxation of Non-Resident Artists or Entertainers

               With effect from 1 January 2014, Section 80 of the Income Tax Act (Chapter
               23:06) has been amended to include artists.

               A 15% withholding tax will be levied on gross fees paid to non-resident
               performing artists.

               The withholding tax is due from a withholding agent, who includes a
               “contractor” of the services of a non-resident artist or entertainer contracted
               to perform in Zimbabwe.

               The amount so withheld shall be remitted to the Commissioner on or before
               the 10th day of the month following that in which the payment was made, or
               within such time as the Commissioner may allow.

               New definition of “payment” for withholding tax on contracts

               With effect from 1 January 2014, the definition of “payment” for the purposes
               of withholding tax on contracts was amended to cover all forms of payment
               under withholding amounts on contracts. It includes payment by cash, barter,
               set-off, crediting a director’s loan account, intercompany debits/credits, and
               other settlement of obligations of whatsoever and in any form.

               Amendment to the definition of “payment” does not clearly define payments
               that would qualify as specific exclusions.

               Extension of intermediated money transfer tax

               With effect from the 1st January 2014, an intermediated money transfer tax of
               USD0.05 is paid per transaction whenever a transfer of funds occur using
               mobile platform service.

               A financial institution as defined in the Thirtieth Schedule will include any
               mobile banking service.

               Automated financial transactions tax

               Automated financial transaction tax of US$0.05 is extended to apply on
               transfer of funds from a financial institution to a mobile platform.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                        Page 11
3.5 CAPITAL GAINS TAX PROPOSALS

               Cession of properties

               Cession of property rights are subject to capital gains tax with effect from
               1st January 2014.

               Membership interest in condominium

               With effect from 1 January 2014, capital gains tax will be levied where a
               person relinquishes a membership interest in a condominium in favour of
               another person.

               Condominium refers to a company, partnership or other association that owns
               immovable property such as flats, apartments or residential units where
               members have a right to occupy properties for accommodation or to a time
               sharing interest in such property.

               Disposal of immovable property through shares
               Legislation will be introduced to curb evasion of Capital Gains Tax through the
               disposal of shares in the company owning the immovable property (only
               proposal not in the final bill).

               Exemptions from Capital Gains Tax

               Market price of shares sold to an indigenisation partner

               With effect from 1 January 2013, disposals of shares under an indigenisation
               scheme are exempt from CGT. The exemption is restricted to:-

               “the amount by which the fair market price of shares sold to an indigenisation
               partner or community share ownership trust or scheme exceeds the actual
               price at which those shares were sold”.

               Capital Gains Tax clearance certificate

               With effect from 1 January 2014, a capital gains clearance certificate is
               required where there has been a sale by cession of properties.

               The same principle will apply to the relinquishing and registration of a
               membership interest in a condominium.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                       Page 12
3.6 CUSTOMS AND EXCISE PROPOSALS

                 Rebate of duty

                 Travellers’ Rebate

                 With effect from 1 January 2014, cooking oil and laundry bar soap are
                 removed from the travellers’ rebate.

                 Manufacturer’s Rebate

                 Clothing Manufacturing Industry

                   The rebate of duty on imported raw materials for use in the manufacture of
                   clothing has been extended by a further period of one year.

                 Beverages Manufacturing Industry
                  15% duty on aluminum cans imported from the region is removed with
                  effect from 1 January 2014.

                 Wines and Spirit Manufacturing Industry
                  In support of the initiative by a local wine producer to modernise plant and
                  machinery to enable production of ciders, it is proposed to ring-fence
                  importation of fermented apple base, under the manufacturers rebate.

                 Sugar Industry-to protect the local sugar industry
                  It is proposed to review upwards, customs duty on imported sugar from 10%
                  to 10% + US$100 per ton.

                 Blanket Manufacturers
                  In support of value addition efforts by the blanket manufacturers, it is
                  proposed to review duty on finished products as follows:-

            Tariff Code       Product             MFN Rate (%)    SADC Rate    Proposed Rate
                                                                                (MFN/SADC)
           5603.1300          Batting                 10              0       40%+US$2.50/kg
           6003.3400          Knitted Lingerie        10              0       40%+US$2.50/kg

           6005.3400          Knitted Fabric          10              0       40%+US$2.50/kg

           6006.3400          Mattress Ticking         5              0       40%+US$2.50/kg

           6301.2000          Blankets           40%+US$1.50/kg       0       40%+US$2.50/kg

                 Baking Industry
                  It is proposed to review downwards the ring-fenced wheat flour imports by
                  bakeries at a lower duty rate of 5% from 7 500 to 5 000 metric tons per
                  month.

                   In order to promote agro-processing, it is proposed that wheat should be
                   wholly produced and milled into flour, in order to qualify under Rules of
                   Origin for purposes of preference.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                       Page 13
Rebate of duty on capital equipment imported by tourism operators

                  To enable the tourism and hospitality industry to implement the expansion
                  and modernisation programme, the rebate of duty on capital goods is
                  reintroduced, with effect from 1 January 2014, for a period of 12 months.

                  Suspension of customs duty on motor vehicles imported by safari
                  operators

                  The suspension of duty on motor vehicles used by safari operators has been
                  reintroduced, for a further period of 12 months with effect from 1 January
                  2014.

                  The terms and conditions that applied to the previous facility will be
                  maintained.

                  Zero rating of imported capital equipment for duty purposes

                  In support of efforts by the local industry to re-tool, Government has zero
                  rated capital equipment for duty purposes.

                  Lapse of the Zimbabwe-South Africa Bilateral Trade Agreement

                  Due to the lapse of the Zimbabwe South Africa Agreement, it is proposed to
                  suspend customs duty preferences under the 1964 Bilateral Trade Agreement
                  between Zimbabwe and the Republic of South Africa, until such a time when
                  the parties agree to reciprocate the application of the Agreement.

                  Exclusion of locally produced capital equipment

                  In order to promote linkages and build synergies between industries, it is
                  proposed to exclude locally produced equipment from rebate of duty under
                  the National Project Status.

                  Excise Duty on ethanol

                  The suspension of duty on ethanol and levy excise duty of US$0.05 per litre
                  of ethanol was lifted, with effect from 1 January 2014.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                       Page 14
STEEL AND PLASTIC MANUFACTURERS
                  In order to provide relief to the steel and plastic manufacturers, duty on
                  finished goods has been reviewed as follows:-

             Tariff                     Product             MFN Rate     SADC Rate      Proposed Rate
             Code                                             (%)           (%)      (MFN/COMESA/SADC)
           3920.2010     Printed Polymers of propylene         10            0              40/30

           3923.2100     Plastics bags of polymers             15           20             40/30

           3924.1000     Plastic basins, buckets, plates       40           15             40/30
                         & mugs

           3924.9000     Plastic basins, buckets, plates       40           15             40/30
                         & mugs

           3917.2320     PVC Pipes                             15           0                15

           3917.2390     PVC Pipes                             5            0                5

           3917.3210     HDPE pipes                            15           0                15

           3917.3220     HDPE pipes                            15           0                15

           3917.3290     HDPE fittings                         15           0                15

           3917.4000     PVC fittings                          15           0                15

           4202.1200     Trolley Case/Back Packs           40+$2.50/kg       5       40+$2.50/kg/25+2.50/kg

           6305.3200     Woven polypropylene bulk bags         15           15             40/30

           6305.3300     Woven polypropylene bags              15           15             40/30

           5407.2090     Woven polypropylene cloth             10           0              40/30

           7321.8200     Paraffin Burners                      40           0              25/20

           7210.4100     Galvanised steel sheets               15           20             25/20

           7323.9290     Cast Iron Pots                        40           0                20

           7615.1900     Aluminium pots, e.t.c                 40           0                20

           7323.9190     Articles of iron, e.t.c.              40           0                20

           7210.4990     Galvanised steel sheets               15           0              25/20

           8716.8010     Wheelbarrows                          25           15             40/30

           8716.9000     Wheelbarrow Parts                     5            0              40/30

               DAIRY AND PROCESSING INDUSTRY

               Duty on milk
               Duty on milk has been reviewed to enhance growth and competitiveness of
               milk production as follows:

               Since powdered milk is an input into the production of fresh milk, yoghurts and
               cheese, among other products, it is proposed to ring-fence importation of this
               product by manufacturers, under a rebate of duty.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                                  Page 15
DUTY ON MILK (KEY RAW MATERIALS)

               Duty on key raw materials has been reduced to enhance competitiveness of
               local dairy processors as follows;

           Tariff Code               Product      MFN Rate (%)          SADC Rate      Proposed Rate
                                                                                        (MFN/SADC)
           1806.2000         Ice cream coating           40                10                5
           7607.1910         Aluminium Foil              15                  0               5

           7607.2000         Backed Aluminium            15                  0               5
                             Foil
           2109.9010         Stabiliser                  10                10                5

           4421.9000         Ice Cream Sticks            25                  5               5

           2008.8000         Strawberry Pulp             25                  0               5

           2008.2000         Pineapple Pulp              25                  0               5

           2008.7000         Peach Pulp                  25                  0               5

               BISCUIT MANUFACTURERS
               Owing to the fact that Biscuit manufacturers have been facing competition
               from imported products, a downward review of duty on imported inputs was
               proposed, as follows;

             Tariff                Product       MFN Rate        SADC Rate       Proposed Rate (MFN/SADC)
              Code                                 (%)
           0910.1200       Ginger Powder            10              0                       5
           0801.1100       Desiccated Coconut       10              0                       5

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                                Page 16
PAINT MANUFACTURERS
               To protect local producers of paint products who face unfair competition from the
               paints imported from the region under preferential agreements and do not attract
               customs duty, an upward review of duty on finished paint products is proposed with
               effect from 1 January 2014 as follows:

              Tariff                  Product         MFN Rate   SADC Rate          Proposed Rate
              Code                                      (%)                          (MFN/SADC)

           3208.1000        Paints Based on              15          0                    20
                            Polyester

           3208.2000        Paints Based on Acrylic      15          0                    20
           3208.9000        Other Paints                 15          0                    20

           3209.1011        Pigmented Water              15          0                    20
                            Thinned
           3209.1091        Other Pigmented              15          0                    20

           3209.1099        Other Paints                 15          0                    20

           3209.9011        Pigmented Water              15          0                    20
                            Thinned

           3209.9019        Other Pigmented Paints       15          0                    20

           3209.9091        Other Pigmented Paints       15          0                    20

           3209.9099        Other Paints                 15          0                    20

           3210.0011        Pigmented Water Paints       15          0                    20
           3210.0019        Non-Pigmented Water          20          0                    20
                            Paints

           3210.0039        Pigmented distempers         20          0                    20
           3210.0091        Other Non-pigmented          15          0                    20

               Metal And Electrical Manufacturers
               In order to level the playing field between locally produced and finished
               products imported under preferential arrangements, it is proposed to review
               duty with effect from 1 January 2014 as follows:

             Tariff                   Product         MFN Rate   SADC Rate      Proposed Rate
              Code                                      (%)         (%)          (SADC/MFN)
           7605.2100        Aluminium Cables             10          0              20/30
           7614.1000        Aluminium Cables             20          0              20/30
           7614.9000        Wire Cables                  20          0              20/30
           7413.0000        Copper Cables                20          0              20/30
           8544.6010        Copper wires                 10          0              20/30

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                          Page 17
RUBBER INDUSTRY
               It is proposed to review duty on finished rubber products as follows:

             Tariff                   Product         MFN Rate        SADC Rate         Proposed Rate
              Code                                      (%)              (%)             (SADC/MFN)
           4009.1100        Mining Hoses                 15               10                 25
           4009.3100        Mining Hoses reinforced      15                   0                 25

           4010.1100        Conveyer belt with           15                   0                 25
                            metal
           4010.1200        Conveyer belt with           15                   0                 25
                            textile
           4012.1190        Other Retreaded Tyres         5                   0           US$2.50/k

            4016.9100       FloorFloor
                                  covering
                                       covering       15 15                   00            2525

               Oil Expressers
               To protect local cooking oil producers from unfair competition from products
               purported to originate within the region which are eligible for preferential
               duty, it is proposed to review duty on raw materials and finished products, in
               order to support local production, as follows:

               Raw Materials

              Tariff                  Description        MFN Rate         SADC Rate of     Proposed MFN/SADC
              Code                                        of Duty            Duty              Rate of Duty
           1518.0090        Emulsifiers                 10                0                5

           4811.9090        Wrappers for Margarine      10                0                5

           3823.1900        Palm Fatty Acid             15                0                5

           2103.9090        Spices                      40                0                10
           1108.1900        Starch                      15                0                10

               Finished Products

             Tariff         Product                     MFN        Rate   SADC Rate (%)              Proposed Rate
              Code                                      (%)                                           (SADC/MFN)
           1515.1920        Vegetable oil                     10                   0                      40

           1517.1000        Margarine                         15                   15                     40

           3401.1100        Soap Tablets                      10                   10                     40
           3401.1900        Soap Bars                         10                   10                     40

           3402.9010        Washing powder (not for           5                    0                      40
                            retail)

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                                      Page 18
4.       TAXATION IN ZIMBABWE: GENERAL OVERVIEW

         The following direct and indirect taxes are levied in Zimbabwe: -

              Income tax which is levied on the annual income of individuals,
               companies, partnerships, trusts and estates.

              Capital gains tax which is imposed on the disposal of immovable
               property and marketable securities.

              Value added tax levied on the supply of goods and services.

              Various levies such as manpower development levy, standards
               development levy, NSSA and workers’ compensation insurance.

              Estate duties on deceased estates.

              Stamp duty on certain documents.

              Stamp duties on transfer of immovable property.

              Customs duties on the importation of goods.

              Excise duties on certain products.

5.       TAXATION OF INDIVIDUALS

         Individuals, wherever resident, are subject to income tax on income derived from
         an actual or deemed Zimbabwean source. Remuneration for services rendered in
         Zimbabwe is taxable in Zimbabwe regardless of where payment is made.

         Taxation of expatriates

         Expatriates are taxable on their Zimbabwean source income irrespective of where
         payment is made. Expatriates may be exempt from tax under the terms applicable
         under double taxation agreements. The usual condition is that the expatriate
         should be in Zimbabwe for less than 183 days in the tax year and payment is made
         offshore.

         Every non-resident employer is required to appoint a local resident agent for
         P.A.Y.E purposes. Work permits for expatriate staff will only be granted on
         condition that the employer is registered for P.A.Y.E through a resident agent.

         Benefits

         The Income Tax Act provides for the taxation of fringe benefits granted by an
         employer in respect of services rendered. The value of the benefit is the cost to
         the employer except for use of furniture or quarters where the benefit is the value
         to the employee.

Prepared By:
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                                                                                     Page 19
Retrenchment / Severance Packages

         With effect from 1 January 2013, it is proposed to review the non-taxable portion of the
         retrenchment package to US$10 000 or one-third of the retrenchment package up to a
         maximum of US$60 000.

         Deemed Motoring Benefits

         With effect from 1 January 2014, section 8(1)(f) of the Income Tax Act [Chapter 23:06] is
         amended by increasing the deemed motoring benefits as follows;”.

            ENGINE CAPACITY                     2013 Rate               2014 Rate

            Up to 1,500cc                       USD 150   per   month   USD 300   per   month
            1,501cc to 2,000cc                  USD 200   per   month   USD 400   per   month
            2,001cc to 3,000cc                  USD 300   per   month   USD 600   per   month
            Above 3,001cc                       USD 400   per   month   USD 800   per   month

         Housing and Accommodation

         The benefit is based on the value to the employee, which is usually the market
         value of the accommodation. The value could, however, be less where the
         employee is forced by work circumstances to stay in a house above his standard.

         Medical Aid Expenses

         The employee is not taxed on employer contributions or refund of medical
         expenses by an employer.

         Approved Employee Share Ownership Trusts

         Where an employee participates in an approved employee share ownership trust,
         any amount received or accrued on the sale or disposal of an employee’s shares are
         exempt from income tax and capital gains tax. The purchase or sale of the shares
         must be done by the trust.

         In order to enjoy the benefits, the trust arrangements have to be notarised in a
         deed and approved by the Commissioner.

         Ring Fencing of tax losses

         Income from employment may not be set off against losses incurred on business
         activities.

Prepared By:
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                                                                                            Page 20
Calculation of tax

         Taxable income of the individual is computed after considering amounts exempt
         from income tax and deductions allowable in terms of the Income Tax Act. While
         taxable income from employment is subject to tax at various rates, income from
         trade or investment is subject to tax at an effective rate of 25,75% [25% plus 3%
         aids levy].

         The amount of tax chargeable is then further reduced by credits, which are
         dependent on the taxpayer’s circumstances.

         Exempt Income

         Income exempt from tax includes the following:

                  Interest received from a financial institution where tax has been withheld
                   at source.

                  Dividends paid by locally incorporated companies.

                  The greater of US$10, 000 or one third of US$60,000 ($20,000) of any
                   retrenchment package received in terms of an approved retrenchment
                   scheme.

                  Contributions paid to a medical aid society by an employer on behalf of his
                   employees and the value of medical treatment provided by an employer for
                   an employee and their dependents.

                  The first US$1,000 of a bonus

                  Pension received by a tax payer aged above 55 years

                  The first $3,000 of rental income received by a tax payer aged above 55
                   years.

                  The first $3,000 of interest received from a financial institution by a
                   taxpayer aged 55 years and above.

         Deductions

         Although fairly limited for employees, these include:

              Expenses incurred in the production of income or for the purposes of trade.
              Subscriptions to business/professional organizations.
              Pension fund contributions by individuals to approved funds including N.S.S.A.
               are allowed against income up to a maximum amount of US$450 per month.

Prepared By:
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                                                                                        Page 21
Prohibited Deductions

         The Income Tax Act specifically prohibits certain deductions. The list includes the
         following:

              Tax payable and interest thereon.
              All domestic and private expenditure.
              Provisions for anticipated or contingent losses or expenditure.
              Entertainment expenditure.
              Expenditure incurred in earning foreign dividends.
              Assessed losses, other than losses arising from mining operations, brought
               forward for more than six years.

         Credits

         The credits to which an individual is entitled to are:

         Mentally/physically disabled person          US$900
         Blind person                                 US$900
         Elderly persons’ credit                      US$900
         Medical expenses                             $1 for every $2 paid

         The age for an elderly person was reduced from 59 years to 55 years with effect
         from 1 January 2010.
         The elderly persons’ credit is reduced proportionately when the period of
         assessment is less than twelve months.

         Employees Tax (PAYE)

         Employers are required to deduct employees tax (PAYE) on all remuneration paid
         to employees.

         Executive directors are deemed to be employees and PAYE should be deducted
         from their salaries.

         Final Deduction System (FDS)

         Under the final deduction system, an employer is directed to withhold PAYE from
         each employee’s remuneration in such a way as to ensure that the amount
         withheld in any year of assessment is equal to the income tax payable by the
         employee concerned.

         An employee whose remuneration is subject to FDS is not required to complete an
         income tax return.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                     Page 22
THE CALCULATION OF ANNUAL TAX PAYABLE – INDIVIDUALS
         [year ended 31st December 2013]

                                                           US$

         Gross Income                                   250 000

         Less Pension & NSSA                             (5 400)

         TAXABLE INCOME                                 244 600

         Tax on Taxable Income per tax tables            94 170

         Less: Medical Aid credit (say)                    (450)

                                                         93 720

         Add: 3% Aids Levy                                2 812

         Total Tax payable                               96 532

         Less:

         PAYE paid                                      (96 400)

         Tax Due                                          (132)

Prepared By:
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                                                                   Page 23
6.       TAXATION OF COMPANIES: INCOME SUBJECT TO TAX

                Companies and trusts, like individuals, are taxed on income derived from an
                 actual or deemed Zimbabwean source.
                 Foreign interest and dividends are deemed to be from a Zimbabwean source.

                Business income is subject to tax at an effective tax rate of 25.75%
                 (25% plus 3% Aids Levy).

                Local company dividends accruing to local companies are exempt from
                 income tax.

                Foreign dividends accruing to local companies are taxed at a flat rate of 20%
                 with relief being granted on any foreign tax suffered.

                Local interest derived from financial institutions is exempt from income tax,
                 but is subject to a final withholding tax of 15%.

         Tax returns filing

         The tax year for all taxpayers is 31st December. Taxpayers who are on the self
         assessment scheme are required to submit their tax returns not later than four
         months after the end of the tax year (i.e. due 30th April).

         Specified taxpayers who are required to be on self assessment include those
         registered or are required to be registered under Category C for VAT as at 31st
         December 2007 or thereafter, or are registered under the Banking Act (Chapter
         24:20) or under the Insurance Act (Chapter 24:07).

         Loss Carryovers

         Assessed losses may be carried forward for a period of 6 years. No loss carry backs
         are allowed. There is no restriction on losses incurred by miners.

         Treatment of Group Companies

         Each group company is treated as a separate taxpayer and losses may not be
         transferred between the different companies. Provision is made for assets to be
         transferred between group companies at income tax values during the course of a
         merger or reconstruction without suffering any tax recoupment. On sale of the
         assets, outside the group, the allowances are then subject to a recoupment.

         Thin Capitalisation

         Any interest, finance charge or other consideration payable by a local branch or
         subsidiary which exceeds a debt to equity ratio of three to one is not allowable for
         tax.

         The disallowed excess is deemed to be a dividend which might be subject to a
         withholding tax.

Prepared By:
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                                                                                        Page 24
Management Fees

         The Income Tax Act restricts the amount deductible for general administrative fees
         payable on intercompany transactions to an amount equal to roughly 1% of the tax
         deductible expenses.

         Any excess disallowed is deemed to be a dividend which can be subject to a
         withholding tax.

         Transfer Pricing

         Tax avoidance provisions are available which adjust the prices of goods and
         services in terms of certain transactions conducted between related parties to
         reflect an arms length price which would have been applied had the transactions
         been concluded on normal commercial grounds between unrelated parties.

         Provisional Tax: Quarterly Payment Dates (QPDs)

         The provisional payment dates for the year ended 31st December 2014 are:

         QPD                                    DUE DATE              INSTALMENT DUE

         1st QPD                                25th March 2014        10%
             nd                                   th
         2        QPD                           25 June 2014           25%
         3rd QPD                                25th September 2014    30%
             th                                   th
         4 QPD                                  20 December 2014       35%
                                                                      100%

Prepared By:
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                                                                                       Page 25
7.       CAPITAL ALLOWANCES

         In calculating taxable income, expenditure and losses (other than that of a capital
         nature) are allowed to the extent to which they are incurred for the purposes of
         trade or in the production of income liable to tax.

         Capital expenditure is allowed in the form of Special Initial Allowance, Wear and
         Tear and Investment Allowance. The applicable rates differ according to the nature
         and category of the asset.

         The rate of S.I.A. is 25% with effect from 1 January 2010. An accelerated rate of
         25% wear and tear is applicable in the next 3 years.

         Immovable assets can only qualify for S.I.A. if they are constructed by the
         taxpayer.

         Donated or inherited assets can only qualify for the lower wear and tear rates.

           Asset                                 Special    Wear and
                                                  Initial    Tear
                                                allowance
                                                     %         %

           Commercial Building                      -         2,5

           Industrial Building                     25          5

           Farm Building and
           Improvements                            25          5

           Staff Housing                           25          5

           Movable Assets                          25          25

         Special Initial Allowance (SIA)

         The rate of SIA in respect of allowable capital expenditure is 25% with effect from
         1 January 2010.

         SIA will be limited to 50% of the cost of fiscalised electronic registers; the other
         50% is allowed as VAT input tax.

         There is no apportionment of SIA.

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                                                                                       Page 26
The taxpayer may elect to claim SIA on capital expenditure incurred on the
         following:-

         -    the construction of farm improvements, industrial buildings,       railway lines,
              staff housing and tobacco barns.

         -    additions or alterations to existing farm improvements, industrial buildings,
              railway lines, staff housing and tobacco barns.

         -    the purchase of new or second hand articles, implements ,machinery or
              utensils.

       SIA is available only in the year in which the asset is used by the taxpayer for the
       purposes of trade.

       With effect from 1st January 2011, a taxpayer who is defined as a “small or medium
       enterprise” will be entitled to S.I.A. of 100% claimable 50% in the first year of
       assessment and 25% in the next two years of assessment.

       Wear and Tear Allowance (W&T)

       The allowance is available on commercial buildings, farm improvements, industrial
       buildings, railway lines, staff housing, tobacco barns, articles, implement, machinery
       and utensils.

       SCRAPPING ALLOWANCE

       The scrapping allowance is available when the income tax value of the asset exceeds
       any proceeds on the sale of the asset.

       Recoupment

       A taxable recoupment arises when the sale proceeds of an asset exceed the income
       tax value of the asset.

       The recoupment is restricted to the original cost of the asset where the sale
       proceeds exceed cost.

       Restrictions

       The following restrictions apply when claiming capital allowances.

       Motor Vehicles

       The maximum amount allowable on the purchase of a passenger motor vehicle is
       USD$10 000.

Prepared By:
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                                                                                         Page 27
Staff Housing

       There is a deductible limit of US$10,000 on staff housing for employees employed at
       a school, hospital, nursing home or clinic.

       The ranking cost of staff housing is USD$25,000.

       Schools, Hospitals, Nursing Homes or Clinics

       With effect from 1 January 2009 the deductible limit on capital expenditure on
       schools, hospitals, nursing homes or clinics is US$10 000 per annum.

       There is no limit on a school, hospital, nursing home or clinic used in connection
       with a taxpayer’s farming operations.

       Mining

       There is a limit of $50,000 in respect of any building used as staff housing by staff employed
       at the mine, school, hospital, nursing home or clinic.

       Any building used mainly as a school, hospital, clinic or nursing home in connection with
       mining operations is also subject to a limit of $50,000.

       There is no restriction on any other building used for mining operations.

Prepared By:
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                                                                                               Page 28
8.     WITHHOLDING TAXES: RESIDENTS / NON RESIDENTS

       RESIDENT SHAREHOLDERS’ TAX [R.S.T.]

       Dividends from Zimbabwean resident companies which are distributed to locally
       resident individuals, trusts and partnerships are subject to a withholding tax of 15%.

       The rate is reduced to 10% for distributions made by companies listed on the
       Zimbabwe Stock Exchange.

       No tax is however withheld on dividends distributed from one Zimbabwean resident
       company to another.

       RESIDENTS’ TAX ON INTEREST (RTI)

       A 15% residents’ tax on interest is payable on interest paid by a financial institution
       to a person who is ordinarily resident in Zimbabwe.

       There is an annual exemption of US$3,000 to interest accruing to individuals aged 55
       years and above.

       NON-RESIDENTS’ TAX ON INTEREST (NRTI)

       The 10% NRTI was repealed with effect from 1st August 2009.

       NON-RESIDENT SHAREHOLDERS’ TAX ON DIVIDENDS (NRST)

       A 15% NRST is deductible from dividends distributed by Zimbabwean companies
       including private business corporations to non-residents. The rate is reduced to 10%
       for distributions made by companies listed on the Zimbabwe Stock Exchange.

       NON-RESIDENTS’ TAX ON FEES (NRTF)

       A 15% NRTF is payable on fees paid to non-residents in respect of technical,
       managerial, administrative or consultative services.

       NON-RESIDENTS’ TAX ON ROYALTIES (NRTROY)

       A withholding tax on royalties is chargeable on royalties paid to non-residents for the
       use of patents, trade marks, formulae, equipment, motion picture etc.

       NON-RESIDENTS’ TAX ON REMITTANCES (NRTR)

       A 15% tax is levied on amounts remitted outside Zimbabwe in respect of allocable
       expenditure, being expenditure of a technical, managerial, administrative, or
       consultative nature incurred by non-residents outside Zimbabwe but in connection
       with their trade in Zimbabwe.

Prepared By:
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                                                                                       Page 29
BANKING INSTITUTION LEVY

       The 5% Banking Institution levy was repealed with effect from 1 January 2010.

       WITHHOLDING TAX ON NON EXECUTIVE DIRECTORS FEES

       Director’s fees payable to non executive directors are subject to a 20% withholding
       tax.

       Non-executive directors will however be expected to complete tax returns and
       declare the fees earned which will be taxed at 25,75% with the 20% withholding tax
       deducted at source being granted as a credit.

       WITHHOLDING TAX ON TENDERS

       A 10% withholding tax is payable on payments of goods and services to suppliers who
       do not have a valid tax clearance certificate.

       WITHHOLDING TAX ON FOREIGN ARTISTS

       With effect from 1 January 2014, a 15% withholding tax will be levied on gross fees
       paid to non-resident performing artists.

Prepared By:
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                                                                                       Page 30
9.     PRESUMPTIVE TAXES

       The following presumptive taxes apply:

       Small Scale Miners

       A presumptive tax of 20% based on the gross value of the mineral, precious metals
       and stones is charged to small – scale miners.

       Taxi Cab Operators

       The presumptive tax is USD$100 per quarter year for each taxicab so operated.

       Commuter Transport Operators

       With effect from 1 January 2010, the presumptive tax of each omnibus per quarter
       year is:-

               USD$150 per bus of a carrying capacity of 8-14 passengers;

               USD$175 per bus of a carrying capacity of 15 – 24 passengers per quarter;

               USD$300 per bus of a carrying capacity of 25 – 36 passengers per quarter;

               USD$450 per bus of a carrying capacity of 37 passengers and above per quarter.

       Commercial water borne vessel operators

       With effect from 1st January 2012, presumptive tax on operators of house boats and
       speed boats is as follows:

               Carrying Capacity            Boats   &   Cabin Proposed Tax Per Quarter
               Cruisers (People)                              (US$)
               1-5                                                 250
               6-15                                                500
               16-25                                             1,000
               26-49                                             1,500
               50 and above                                      2,000

       Operators of fish rigs will be liable to pay US$350 per rig per quarter with effect
       from 1 January 2012.

       Payment for each Quarter must be made by 20th January, 20th April, 20th July and
       20th October of each year of assessment.

       Informal Traders

       The presumptive tax is 10% of the rent paid by the informal trader.

Prepared By:
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                                                                                           Page 31
Hair Saloons

       The presumptive tax is USD$1,500 per quarter.

       Cross Border Traders

       The presumptive tax is 10% of the value for duty purposes of the commercial goods
       being imported.

       Restaurants and Bottle Stores

       With effect from 1 January 2010, operators of restaurants or bottle stores not
       registered for tax purposes will pay a presumptive tax of US$300 per quarter.

       Cottage Industry Operators

       With effect from 1 January 2010, operators of cottage industries not registered for
       tax purposes will pay a presumptive tax of US$300 per quarter.

Prepared By:
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                                                                                    Page 32
10. CAPITAL GAINS TAX

       Immovable property and unlisted shares acquired prior to 1st February 2009 are
       subject to a final 5% capital gains tax on gross proceeds.

       Gains from marketable securities listed on the Zimbabwe Stock Exchange are exempt
       from capital gains tax but subject to a final 1% withholding tax on gross proceeds.

       A capital gains tax of 20 per cent is chargeable on gains arising from the sale of
       immovable property and unlisted securities which were acquired after
       1st February 2009.

       Allowable deductions in the determination of a capital gain are the cost of the asset,
       additions thereto, and an inflation allowance at the rate of 2½% per annum.

       Mortgage bond interest or any other interest which was incurred in financing the
       purchase of a specified asset can also be claimed if the amount is not allowable for
       income tax purposes.

       A 15% capital gains withholding tax is payable on disposal of immovable property,
       while a 5% withholding tax is payable on unlisted shares.

       Persons over 55 years are not taxed on capital gains arising from the sale of a
       principal private residence.

       Capital gains arising from the sale of marketable securities (unlisted) by persons over
       55 years of age are exempt from tax in respect of the first US$1,800.

       Where a specified asset is sold under a suspensive sale, an allowance is granted for
       installments not yet due. The allowance is normally claimed on immovable property
       sold under deed of sale agreements.

       CAPITAL GAINS TAX ELECTIONS

       Legislation allows for the transfer of immovable property or marketable securities
       without imposing tax on the seller in certain circumstances. Such circumstances are
       as follows: -

                   sale of a principal private residence where proceeds are used to acquire
                    another principal private residence;

                   transfer between spouses;

                   transfers in a reconstruction scheme or merger and is between companies
                    under the same control;

                   transfer by a branch of a foreign company to a company incorporated in
                    Zimbabwe;

                   transfer of shares in exchange for a marketable security for no cash
                    consideration in a scheme of reconstruction or merger;
Prepared By:
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                                                                                       Page 33
    transfer by an individual to a company controlled by him if the asset
                    continues to be used for purposes of trade by the company;

                   when immovable property used for trade purposes is disposed of and is
                    replaced by another immovable property used for trade purposes as well,
                    then any gain on the disposal can be postponed to the extent that the sale
                    amount is used to purchase the new property.

                   transfers by a company to a private business corporation into which the
                    company has been converted into or vice versa, in the course of or in
                    furtherance of that conversion.

       It should be noted that capital gains tax is not levied on transfer by the executor of a
       deceased estate or on gains by a licensed investor if the asset formed the whole or
       part of the investment to which the licence relates.

Prepared By:
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                                                                                        Page 34
11. VALUE ADDED TAX (VAT)

       VAT is an indirect tax levied at 15% on the supply of goods and services. VAT is also
       levied on the importation of goods and services in certain circumstances.

       Exempt Supplies

       Exempt supplies are supplies that are exempt from VAT.

       Common examples of exempt supplies are: -

             supply of financial services
             supply of educational services
             supply of health services
             renting of residential accommodation

       Taxable Supplies

       Taxable supplies are charged to tax at either the zero rate or the standard
       rate of 15%.

       Zero Rated Supplies

       Zero rated supplies are charged to tax at the zero percent.

       Common examples of zero rated supplies are:

             Certain basic foodstuffs e.g. milk, bread, sugar, salt
             Certain goods used for farming purposes
             Exported goods and services
             The sale as a going concern between two VAT registered traders.

       VAT on importation of goods

       VAT is chargeable and payable on the importation of any goods into Zimbabwe.

       Goods are deemed to be imported on the date the goods are cleared. VAT is paid at
       the same time as customs duty.

       With effect from 1 January 2010, section 39 of the Value Added Tax Act has been
       amended to include the levying of penalties and interest for failure to pay VAT due
       on imported services.

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                                                                                      Page 35
Imported Services

       VAT is payable on the supply of an imported service. An imported service is one that
       is made by a supplier who is not a resident of Zimbabwe to a recipient who is a
       resident of Zimbabwe and who does not utilize the service for making taxable
       supplies.

       With effect from 1 January 2010, VAT on imported goods will be based on value for
       duty purposes plus any duty excluding surtax levied in terms of the Customs and
       Excise Act.

       The recipient of the services must within 30 days of the time of importation declare
       and pay the VAT to ZIMRA.

       Collection of tax on exportation of unbeneficiated chrome

       With effect from 1 January 2010, VAT at 15% will be payable on the
       exportation of unbeneficiated chrome (chrome and chrome fines).

       No input tax credit may be claimed on the VAT.

       Fiscalised Electronic Registers

       With effect from 1 October 2010 taxpayers in category C are required to record
       transactions through fiscalised electronic registers. The cost of fiscalised electronic
       registers is zero rated.

       Input Tax

       No credit for input VAT may be claimed in respect of the following: -

           goods or services acquired exclusively for the making of exempt supplies

           sporting and social club fees and subscriptions

           entertainment expenditure.

       Input tax credit may only be claimed upon production of a valid tax invoice.

       50% of the cost of the acquisition of fiscalised electronic registers by a registered
       operator qualifies for an input tax deduction.

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                                                                                       Page 36
12. PAYROLL TAXES

       12.1        P.A.Y.E.

                   Employers are required to withhold P.A.Y.E. from employees’ remuneration
                   according to the P.A.Y.E. tax deduction tables unless otherwise instructed
                   by a tax deduction directive from the Commissioner General.

                   P.A.Y.E. must be remitted to ZIMRA by the 10th day of the month following
                   the month in which the P.A.Y.E. was withheld.

       12.2        SOCIAL SECURITY

                   The state operated pension scheme is known as the National Social Security
                   Authority (NSSA). The rate is 3,5% insurable earnings with a cap of monthly
                   earnings of $700.

       12.3        WORKERS COMPENSATION INSURANCE

                   Employers are required to insure their employees against accident at work
                   that could result in disability or death. Employers are therefore required to
                   pay monthly, to NSSA an amount of workers compensation insurance.

                   The amount varies according to the sector of the industry.

       12.4        STANDARDS DEVELOPMENT LEVY

                   This is a levy paid towards the Standards Association of Zimbabwe.

                   Payments are made every quarter at a rate of 0,50% of the quarterly wage
                   bill.

       12.5        ZIMDEF TRAINING EMPLOYER

                   Every employer is required to pay monthly a manpower levy of 1% of the
                   monthly wage bill to the Zimbabwe Manpower Development Fund.

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                                                                                         Page 37
13. ESTATE DUTY
    Estate duty is chargeable on the net value of a deceased person’s estate. The
    applicable rates vary on a sliding scale from 1.02% per $100 or part thereof, up to a
    maximum of 5% where the dutiable amount is USD$50,000 or above.

       EXEMPTIONS
       Where there is a surviving spouse or minor child the value of a family home as
       defined is not subject to estate duty.

       Transfer duty is not chargeable where a property is transferred to a beneficiary who
       is a spouse or blood-relative or adopted child of the deceased or to a trustee.

       Donations may be exempt if they were made 5 years or more prior to death.

       Payments from policies specifically taken out to pay estate duty are not taxable only
       to the extent of the duty payable.

14. STAMP DUTY
    Stamp duty is imposed on bonds, broker’s notes, cheques, policies of insurance and
    registration in a Deeds Registry on the acquisition of immovable property.

15. CUSTOMS DUTY
    Customs duty is levied on all goods imported. The effective rates of duty range from
    0% to 100%.Import tax is levied on most goods at the VAT standard rate of 15%. In
    general, Zimbabwe imposes restrictions on the importations of a range of goods
    which require import permits or licences e.g. agricultural products and explosives.

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                                                                                     Page 38
16. TAX RATES

       Summary of Tax Rates 2013 – 2014

       Income tax                                                          2013   2014
       Companies and Trusts                                                   %      %
       Basic Rate                                                            25     25
       Aids Levy                                                               3     3
       Effective rate                                                      25,75 25,75

       Capital Gains Tax
       Listed securities                                                    nil        nil
       Unlisted securities                                                 20/5      20/5
       Immovable property                                                  20/5      20/5
       Principal private residence (over 55 years)                           nil       nil

       Withholding Taxes
       Residents and non resident shareholders tax:-
       - Zimbabwe Stock Exchange listed company                               10       10
       - Any other Company                                                    15       15
       Residents tax on Interest                                              15       15
       Non-Residents’ tax on Interest                                        nil       nil
       Fees and Royalties                                                     15       15
       Remittances                                                            15       15
       Non executive director’s fees                                          20       20

       Capital gains withholding tax
       - Immovable property                                                   15       15
       - Listed shares                                                         1        1
       - Other shares                                                          5        5

       Tobacco Levy
       - Sellers                                                               nil     nil
       - Buyers                                                               1,5      1,5

           Listed shares are subject to a final withholding tax of 1% with effect from 1st
            August 2009.

           Capital gains withholding tax rate on assets purchased prior to 1st February 2009
            in Zimbabwean dollars is 5%.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                        Page 39
Special Income Tax Rates
                                                          2013 2014
       BOOT/BOT Arrangements
       - first 5 years                                      0     0
       - next 5 years                                      15    15
       - thereafter                                        25    25

       Industrial Park, Developer
       - first 5 years                                      0     0
       - thereafter                                        25    25

       Taxable income of a tourist facility in an
       Approved development zone
       - first 5 years                                      0     0
       - thereafter                                        25    25

       Taxable income from operation of tourist
       Facility 60% or more of turnover consist of
       Foreign currency receipts                            20   20

       Taxable income from manufacturing or
       processing company which exports 50% or              20   20
       more of its outputs

       Taxable income of pension fund trade                15    15
       or investment

       Taxable income of individual from trade             25    25
       or investment

       Taxable income of company or trust derived          25    25
       from mining operations

       Taxable income of holder of special mining lease    15    15

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                      Page 40
17. DOUBLE TAXATION AGREEMENTS

       The following agreements are in force and the applicable withholding taxes are as
       follows: -
                        DIVIDENDS          FEES          ROYALTIES
                            %                %                %

           Botswana                   10        10             10

           Bulgaria                10/15        10             10

           Canada                     10        10             10

           France                     10        10             10

           Germany                 10/15        7,5            7,5

           Iran                       5         15              5

           Malaysia                   10        10             10

           Mauritius                  10        15             15

           Namibia                  5/10        15             10

         Netherlands               10/15        10             10

           Norway                     15        10             10

           Poland                     10        15             10

          South Africa                15        15             15

           Sweden                     15        10             10

           UK                       5/15        10             10

         Normal rate               15/10        15             15

       Reduced rate on non-residents shareholders tax applies to a dividend
       declared by Zimbabwean companies to non-resident companies
       controlling 25% or more of the voting power of the paying company.

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                  Page 41
16.    ROYALTIES

       Diamond.................................15

       Other precious stones.................10

       Platinum.................................10

       Gold: Small scale miners..............3

       Other miners.............................7

       Other precious minerals................4

       Base metals...............................2

       Industrial metal..........................2

       Coal bed Methane.......................2

       Coal........................................1

        Gold produced by small scale miners 3%
        Gold produced by other miners 7%

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                       Page 42
19. COMPARATIVE RATES OF TAXES PAYABLE IN CERTAIN
    SOUTHERN AFRICAN STATES

                                 Botswana       Malawi       South      Zambia        Zimbabwe
                                                             Africa
INDIVIDUAL TAX

Maximum rate                     25%            30%          40%        35%           51,5%
Level     of   taxable           P144 000       MWK600 000   R673 101   K70 800 000   US$240 000
income      at   which
maximum rate applies
COMPANY TAX
Manufacturing – 50%              15%            18%          28%        35%           20%
Normal non mining,               22%            30%          28%        35%           25.75%
local
Non-resident Branch              30%            35%          33%        35%           -
Mining and other                 22% - 55%      30%          28%        30-45%        15% - 25%
Cellphone Operators              22%            33%          28%        35%           25,75%
OTHER TAXES
Distributed Profits Tax          -              -            10%        15%           -
CGT                              22%            -            10%/14%    -             15%
VAT                              12%            16,5%        14%        16%           15%
NRST                             7,5%           5%/10%       -          15%           10%/15%
NRTI                             15%            15%          NIL        15%           NIL
RTI                              10%            20%          -          15%           15%
NRTF                             15%            15%          -          20%           15%
Royalty Tax                      10%            15%          12%        15%           15%
(withholding tax)
Dividend withholding             7,5%           10%          15%        15%           10% - 15%
tax
Rental Income                    5%-10%         -            -          10%           0%- 10%

Non – Resident                   -                           15%        20%           15%
entertainers

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                            Page 43
MEMBER FIRMS WORLD WIDE

-   Algeria                            -        Georgia              -   Oman
-   Angola                             -        Germany              -   Pakistan
-   Argentina                          -        Gilbraltar           -   Panama
-   Aruba                              -        Greece               -   Paraguay
-   Australia                          -        Greenland            -   Peru
-   Austria                            -        Guatemaia            -   Phillipines
-   Bahamas                            -        Guernsey             -   Poland
-   Belarus                            -        Hungary              -   Portugal
-   Belgium                            -        India                -   Qatar
-   Boliva                             -        Indonesia            -   Romania
-   Botswana                           -        Ireland              -   Russia
-   Brazil                             -        Isle of man Israel   -   Rwanda
-   British Virgin Isles               -        Italy                -   Saudi Arabia
-   Bulgaria                           -        Jamaica              -   Senegal
-   Burundi                            -        Japan                -   Serbia
-   Cambodia                           -        Jersey               -   Seychelles
-   Canada                             -        Jordan               -   Singapore
-   Cape Verde                         -        Kazakhstan           -   Slovak Republic
-   Caribbean Region                   -        Kenya                -   Slovenia
-   Cayman Islands                     -        Korea                -   South Africa
-   Chile                              -        Latvia               -   Spain
-   China (Hong Kong)                  -        Lebanon              -   Sri Lanka
-   China                              -        Liechtenstein        -   St Marten
-   Colombia                           -        Lithunia             -   Suriname
-   Comoros                            -        Luxemburg            -   Sweden
-   Croatia                            -        Macau                -   Switserland
-   Curacao                            -        Madagascar           -   Taiwan
-   Cyprus                             -        Malawi               -   Thailand
-   Czech Republic                     -        Malaysia             -   Tanzania
-   Denmark                            -        Malta                -   Trinidad & Tobado
-   Dominican Republic                 -        Mauritius            -   Tunisia
-   Dutch Caribbean                    -        Mexico               -   Turney
-   East Africa                        -        Morocco              -   Turkmenstan
-   Ecuador                            -        Mozambique           -   Uganda
-   Egypt                              -        Nambia               -   United States of America
-   El Salvador                        -        Netherlands          -   Venezuela
-   Estonia                            -        New Zealand          -   Veitnam
-   Finland                            -        Nigeria              -   Zambia
-   France                             -        Northern Ireland     -   Zimbabwe
                                       -        Norway

Prepared By:
BDO Tax & Advisory Services (Private) Limited
                                                                                             Page 44
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