Online Reporter
By Business Correspondent
Treasury’s confirmation that the range of taxes payable exclusively in ZiG is set to widen is a welcome and logical next step in the currency programme.
Finance, Economic Development and Investment Promotion Minister Professor Mthuli Ncube told the Sunday Mail ahead of this week’s 2026 Mid-Term Budget and Economic Review Statement that the move forms part of an ongoing effort to lift demand for the local currency and pointed to a currency that has, in his words, been “very stable” since its 2024 introduction.
That stability is itself the precondition for everything that follows: it is difficult to ask businesses to hold a currency confidently until it has shown it can hold its value, and the Reserve Bank’s own figures – ZiG’s share of electronic payments rising from roughly 26 percent at launch to between 35 and 40 percent today – suggest the groundwork is taking hold.
The reasoning behind expanding ZiG – only tax obligations is sound, according to legal practitioners.
Monetary authorities have identified eight conditions for an eventual mono-currency transition and six are reported to have been met, leaving currency demand and reserve cover outstanding. Taxes are one of the most reliable ways to build demand, precisely because they recur every month across the formal economy. Requiring more of them to be settled in ZiG gives the currency a natural, built-in buyer.
There is one further piece that would make the case complete, and it sits with how historic ZiG tax payments are treated once a year is reopened. Between 2019 and 2024, Zimbabwe’s monetary framework changed several times, while the tax statutes governing how multi-currency liabilities should be computed did not keep pace. In the gap this left, ZIMRA’s own forms, notices and administrative guidance became the practical framework most taxpayers relied on when filing. Some taxpayers, reading the underlying charging provisions differently, took an alternative but reasonable view of what the law required. Both groups were acting in good faith on an unsettled question.
The broader principle at stake here has already drawn scrutiny from the legal profession, albeit in a related dispute over ZIMRA’s dual-currency VAT assessments. Legal practitioner, Ms Paida Makoni, argued that reliance on administrative notices, rather than clear statutory provisions, cannot lawfully expand a taxpayer’s obligations, invoking the principle of nullum tributum sine lege – no taxation without law – and noting that the Zimbabwe Revenue Authority’s mandate, as affirmed in Curverid v Zimra (SC 114/25), is confined to what is explicitly set out in statute.
Ms Makoni described some resulting assessments as amounting to “supplementation rather than correction,” and points, alongside other practitioners, to High Court decisions such as Woodthorpe Investments v Zimra (HH 220-26) as setting out what has been termed a nullity pathway: an assessment issued on the wrong legal authority is void from the outset. The same underlying question — whether administrative practice can stand in for clear legislation when a taxpayer’s liability is being recalculated — runs through the ZiG reassessment cases as much as it does the VAT dispute.
From 2022, some of these years began to be reopened and restated in United States dollars. Where that recomputation showed a shortfall, the ZiG already paid was not always credited back at the value it held on the day it was received — a value that, after intervening inflation or exchange-rate movement, was often considerably lower by the time of restatement. The result is not a dispute about whether tax was properly due; Parliament is fully entitled to prescribe how future obligations should be settled. It is a narrower, more technical question of measurement: whether local-currency payments the State has already received are recognised at the value they carried when it received them.
This is worth resolving well, because it is the natural companion to the demand-side measures already under way — the 50 percent ZiG requirement on Quarterly Payment Dates, the shift of public sector supplier payments into local currency, and the reduced Intermediated Money Transfer Tax rate on ZiG transactions. Those measures ask businesses to hold and transact in ZiG with confidence. Applying the same value-recognition standard to historic ZiG tax payments would reinforce that confidence rather than complicate it and would remove a source of uncertainty for compliant taxpayers ahead of the reforms Treasury is preparing to announce.
A modest, practical path would achieve this. Backdated assessments could be settled on a value-symmetry basis, crediting local-currency receipts at their worth when paid. Going forward, Parliament could set out clearly and prospectively how multi-currency liabilities are to be measured, removing the ambiguity that produced diverging taxpayer positions in the first place. Taxpayers who followed ZIMRA’s published guidance, or took a defensible view of unclear law at the time, could be treated as having reasonably complied rather than re-assessed years later against a standard adopted after the fact. And genuinely contested cases could be allowed to run their course before recovery action is enforced, so that the outcome reflects a settled legal position rather than an administrative one.
None of this detracts from the currency programme; it strengthens it. Reserve Bank Governor Dr John Mushayavanhu has made the point that Government, as the country’s largest economic agent, sends signals through its own conduct that ripple across every sector of the economy. That signal runs through the tax system as much as through public procurement. Aligning how ZIMRA recognises historic ZiG payments with the confidence the Government is asking the private sector to place in the currency would close the loop on an already well-designed programme, and would let the expanded ZiG tax net do its full work of building durable, rather than merely compliant, demand for the local currency.
