Back to top
Zalari has raised $2 million USD in a founding round led by Nyamaropa Technologies
Harare High Court

E (Private) Limited v Zimbabwe Revenue Authority

HH 10-22

Case Details

Court
Harare High Court
Date
6 January 2022
Citation
HH 10-22
Neutral Citation
[2022] ZWHH 10
Outcome
unknown
Case Type
Appeal

Bench

Presiding
ZIYAMBI AJ
Full Bench
ZIYAMBI AJ
Areas of Law
Tax LawAdministrative Law
Keywords
Non-residents tax on feesTechnical servicesRoaming and interconnectionDouble taxation agreementWithholding tax
Tags
Income TaxNon-Residents TaxWithholding TaxTelecommunicationsRoaming FeesInterconnection Fees
legislation
Statutes Cited
  • Income Tax Act
  • Income Tax Act
  • Income Tax Act
  • Income Tax Act
ai analysis
Case Summary

Key Issues

  • {"issue_text":"Whether roaming and interconnection fees should be subject to non-residents tax on fees","issue_type":"law","dispositive":"yes","related_facts":"Nature of telecom services, definition of technical services"}
  • {"issue_text":"Whether fees paid to companies in countries with DTAs are taxable in Zimbabwe","issue_type":"law","dispositive":"yes","related_facts":"Existence of DTAs, Article 22 provisions"}
  • {"issue_text":"Whether there is legal basis for 5% penalty imposition","issue_type":"law","dispositive":"no","related_facts":"Paragraph 6(1)(b) of Schedule"}
This summary was generated by AI. Use Zalari to read the full judgment.
background
Facts of the Case

Background

A telecommunications company appealed against additional withholding tax assessments and penalties imposed by ZIMRA for failure to deduct non-residents tax on fees paid to foreign telecoms companies for roaming and interconnection services.
Read the full judgment, get AI analysis, and find related cases
Open in Zalari →
Zalari
Legal Intelligence
for Africa.
research
Browse All CasesLaw ReportsSupreme CourtConstitutional CourtLabour Court
high court
Harare High CourtBulawayo High CourtMutare High CourtMasvingo High CourtChinhoyi High Court
product
FeaturesPricingUse Cases
company
AboutContact
resources
LegalTerms of ServicePrivacy PolicySecurityZALARI ConventionZALARI 1.0
© Copyright DeepCounsel – Powered by
Nyamaropa
Zalari is Zimbabwe and Southern Africa's leading AI-powered legal research platform, built by DeepCounsel and powered by Nyamaropa Technologies. Search Zimbabwe Supreme Court and High Court case law instantly, get AI-generated answers with full source citations, and access the most comprehensive corpus of Zimbabwean and Southern African jurisprudence available online. Zalari is the go-to legal AI platform for attorneys, advocates, law students, judges, and corporate counsel across Zimbabwe and South Africa — delivering faster research, smarter insights, and a competitive edge in legal practice. Zalari does not provide legal advice. Always consult a qualified legal practitioner for advice specific to your situation. © 2026 DeepCounsel — a legal technology company democratising access to legal knowledge in Africa.