Delta Corporation’s tax dispute with the Zimbabwe Revenue Authority (ZIMRA), involving assessments totalling approximately US$97 million, is now before the Special Court for Income Tax Appeals.
The dispute is over value-added tax (VAT) and income tax assessments covering the period from 2019 to 2022, including an earlier US$74 million claim.
Delta has challenged the assessments, arguing that ZIMRA failed to properly credit or adjust for local currency payments made during periods of hyperinflation.
Presenting the group’s financial performance for the six months ended September 30, 2026, Delta chairman Todd Moyo said that although the validity of the assessments for the 2019 to 2021 period had been confirmed, their correctness and calculation remained contested.
He said the issues still before the fiscal appeal court included the quantification, methodology, apportionment and currency characterisation of the assessments.
“The High Court declaratory application concerning the 2024 VAT assessments also remains pending, while further proceedings are being considered in relation to the March 2026 additional income tax assessment for the 2021 year. Routine audits and reviews of other tax heads may continue in the normal course of business,” Moyo said.
Moyo said Delta had paid US$22.8 million towards the disputed liabilities as at September 30, 2026, in line with the “pay now, argue later” principle and existing payment arrangements.
He expressed hope that any revisions to the payment plan would be rational and in the national interest, taking into account that the principal amounts had been paid in legal tender at the time, based on what the company considered the best reasonable interpretation of the law.
Delta also believes that its US dollar-denominated Treasury Bills could be accepted by the Government to offset any portion of the liability that may ultimately become payable.
Despite the dispute, Moyo said the company remained committed to meeting its tax obligations and had paid more than US$193 million in taxes in Zimbabwe during the half-year period.
This represented a 31% increase compared with the same period last year.
“The ambiguities in the tax legislation remain pervasive, thereby creating risks of further disagreements in interpretations under the existing tax framework,” he added.
Read the original article on New Zimbabwe.
