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Supreme Court

Standard Chartered Bank Zimbabwe Limited v Zimbabwe Revenue Authority

[2018] ZWSC 23

Case Details

Court
Supreme Court
Date
20 March 2018
Citation
[2018] ZWSC 23
Judgment No.
SC 145/15
Outcome
unknown
Case Type
Appeal

Bench

Presiding
ZIYAMBI AJA
Full Bench
GUVAVA JAMAVANGIRA JAZIYAMBI AJA
Areas of Law
Tax lawBanking lawAdministrative law
Keywords
Retrenchment costsOffshore interestNostro chargesWithholding taxIncome Tax Act
Tags
Income taxBankingOffshore loansNostro accountsWithholding tax
legislation
Statutes Cited
  • Income Tax Act [Chapter 23:06]
  • Income Tax Act [Chapter 23:06]
  • Income Tax Act [Chapter 23:06]
  • Labour Act [Chapter 28:01]
ai analysis
Case Summary

Key Issues

  • {"issue_text":"Whether appellant was entitled to claim staff retrenchment costs in 2009 tax year","issue_type":"mixed","dispositive":"no","related_facts":"Retrenchment exercise conducted in 2009, Ministerial approval granted in 2010"}
  • {"issue_text":"Whether appellant correctly held to have earned interest on offshore loans to customers","issue_type":"mixed","dispositive":"no","related_facts":"Facility letters named appellant as lender, customers paid interest to appellant"}
  • {"issue_text":"Whether nostro account charges liable to withholding tax under s 30 and 17th Schedule","issue_type":"law","dispositive":"no","related_facts":"Foreign banks debited charges for administrative services on nostro accounts"}
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background
Facts of the Case

Background

Standard Chartered Bank Zimbabwe Limited appealed against income tax assessments for 2009-2011 concerning three issues: deductibility of staff retrenchment costs, taxation of interest on offshore loans to customers, and withholding tax on nostro account charges.
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