Delta pursues resolution on $73 million tax dispute with ZIMRA

Business Reporter

Beverages manufacturing giant Delta Corporation continues to pursue a favourable legal outcome to its protracted tax dispute with the Zimbabwe Revenue Authority (ZIMRA), including claims from additional assessments amounting to US$73 million.

According to the group’s trading update for the first quarter ended June 30, 2025, Delta is actively pursuing ongoing appeals and new cases in various courts as it battles ZIMRA over Value Added Tax and Income Tax liabilities from 2019 to 2022.

According to the beverage maker’s financial year 2026 (FY26) first quarter to June 2025 trading update released this week, Delta’s enduring grievance centres on ZIMRA’s assessments, which the company disputes and argues fail to adequately account for payments earlier made in local currency.

Among Delta’s contentions are alleged “inconsistencies” in ZIMRA’s Tax Revenue Management System (TaRMS), with Delta asserting a misallocation of current tax payments that seemingly disregards specific returns lodged by the taxpayer.

Despite adverse judgements from the High Court and the Supreme Court in earlier phases of the dispute, Delta’s legal counsel continues to seek a favourable outcome to the wrangle.

In the trading update, Delta further noted that a recent attempt to gain access to the Constitutional Court was declined, with the highest court directing that all the unresolved legal issues should continue to be pursued through the fiscal courts.

In line with the “pay now, argue later” principle and pre-existing payment plans, Delta said it had remitted a total of US$11,6 million as of June 30, 2025.

The company has articulated its expectation that any future adjustments to the payment plan will be “rational, with due consideration of the financial health of the business and the fact that the principal amounts were fully paid in legal tender at the relevant periods, based on the best available interpretation of the legislation.”

The trading update also highlighted Delta’s significant exposure to the Government through Treasury Bills, suggesting these could be utilised to offset any portion of the tax liability that is ultimately deemed payable.

The company’s tax contribution to the Zimbabwean fiscus remains substantial, with over US$72 million paid in taxes for the quarter ended June 30, 2025, a 10 percent increase year-on-year.

Management, according to the trading update, confirmed it remains in continuous engagement with ZIMRA, while simultaneously appealing what it describes as “legal and factual issues of the assessments and the judgments,” under the guidance of tax experts and legal counsel. Delta has consistently maintained that these assessments, should they materialise as per the current figures, would have a “material impact” on the group’s operations.

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