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Harare High Court
BCM (PVT) LTD v ZIMBABWE REVENUE AUTHORITY
HH 214-21
Case Details
Court
Harare High Court
Date
28 April 2021
Citation
HH 214-21
Neutral Citation
[2021] ZWHH 214
Outcome
unknown
Case Type
Appeal
Bench
Presiding
ZIYAMBI AJ
Full Bench
ZIYAMBI AJ
Areas of Law
Tax LawAdministrative Law
Keywords
Value Added TaxTax assessmentFair value adjustmentsAdvisory servicesZero-rated supplies
Tags
VATTax assessmentFiscal appeal
legislation
Statutes Cited
- Immigration Act 1971
- Immigration and Asylum Act 1999
- Nationality, Immigration and Asylum Act 2002
- European Convention on Human Rights
- Human Rights Act 1998
- Extradition Act 1989
- Extradition Act 2003
- Police and Criminal Evidence Act 1984
- Criminal Justice Act 1988
- Criminal Justice and Public Order Act 1994
- Asylum and Immigration Appeals Act 1993
- Asylum and Immigration Act 1996
- Special Immigration Appeals Commission Act 1997
- Anti-terrorism, Crime and Security Act 2001
- Nationality, Immigration and Asylum Act 2002
- Immigration, Asylum and Nationality Act 2006
- UK Borders Act 2007
- Criminal Justice and Immigration Act 2008
- Borders, Citizenship and Immigration Act 2009
- Immigration Act 2014
- Immigration Act 2016
ai analysis
Case Summary
Key Issues
- {"issue_text":"Whether amounts taxed as sundry income for 2011-2013 were fair value adjustments","issue_type":"fact","dispositive":"no","related_facts":"Financial statements showed sundry income, appellant claimed fair value adjustments"}
- {"issue_text":"Whether $100,000 subjected to VAT for 2011 was correctly classified as advisory fees","issue_type":"fact","dispositive":"yes","related_facts":"No documentary evidence of $100,000 in financials"}
- {"issue_text":"Whether $608,191 and $237,568 for 2013 were share income and dividend income","issue_type":"fact","dispositive":"no","related_facts":"Amounts not reflected in financial statements under claimed headings"}
- {"issue_text":"Whether $2,447,092 for 2014 was supply to non-resident qualifying for 0% VAT","issue_type":"law","dispositive":"no","related_facts":"Services rendered for Atlas Mara but also benefited BancABC (local entity)"}
- {"issue_text":"Whether $3,321,293 for 2015 was fair value gain","issue_type":"procedural","dispositive":"no","related_facts":"Issue not included in grounds of appeal"}
- {"issue_text":"Whether 75% penalty was appropriate","issue_type":"discretionary","dispositive":"no","related_facts":"No grounds of appeal on penalty"}
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background
Facts of the Case
Background
The appellant, an investment holding company, appealed against VAT assessments issued by ZIMRA for the period 2011-2015. ZIMRA had assessed that various income streams including sundry income and advisory fees should have been subjected to VAT but were not declared. The assessments totaled $3,397,322.26 including a 75% penalty.
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