Key Impacts of SI 81 of 2025
Statutory Instrument (SI) 81 of 2025, officially designated as the Finance (Due Dates for Submission of Returns and References to the Zimbabwe Dollar) Regulations, 2025, represents a significant restructuring of Zimbabwe’s tax compliance framework. The instrument was enacted by the Minister of Finance, Economic Development and Investment Promotion, under the legal authority granted by section 49 of the Finance (No. 7) Act, 2024.
The SI serves a dual, interconnected function critical to the government’s fiscal strategy: first, it establishes a comprehensive and highly standardized schedule of due dates for the submission and remittance of nearly all major tax returns administered by the Commissioner-General of the Revenue Authority.
Second, Clause 3 of the regulations formally addresses the statutory definition of currency, legislatively mandating that “Any reference to the Zimbabwe dollar in any of the revenue acts shall be construed to be reference to the local currency“. This legal equivalence is fundamental to the operational enforcement of the country’s new currency regime.
The implementation of SI 81/2025 introduces several high-impact operational and financial risks for registered taxpayers. The most immediate concern is the aggregation and compression of remittance deadlines. The vast majority of transactional and withholding tax (WHT) obligations are now consolidated into an extremely restrictive deadline: the 5th day of the following month. This narrow window creates intense pressure on;
- payroll processing,
- month-end closing procedures, and
- corporate treasury liquidity planning.
Compounding the deadline challenge is the enforcement of the Zimbabwe Gold (ZiG) currency, officially the local currency. The regulatory shift necessitates meticulous dual-currency compliance, requiring organizations to perform reconciliation and remittance in both the ZiG and the United States dollar (USD) . Errors or delays in this complex reconciliation process, especially given the compressed timelines, significantly heighten the penalty exposure. Employers that fail to adapt their systems and processes face statutory penalties that can escalate up to 100% of the unpaid amounts, plus compounding interest charges . The regulations effectively mandate an overhaul of corporate finance systems to align with these aggressive new compliance requirements.
The Mandate of SI 81/2025
Statutory Instrument 81 of 2025 operates under the explicit grant of power provided in Section 49 of the Finance (No. 7) Act, 2024. This foundational legal placement signals that the standardization and tightening of tax submission dates are not merely administrative changes but are core instruments in the government’s 2024/2025 fiscal strategy, which emphasizes rigorous domestic resource mobilization and improved tax collection efficiency.
The regulations apply universally to all returns under the various revenue acts administered by the Commissioner-General of the Revenue Authority under the Revenue Authority Act .This standardization ensures consistent enforcement across the entire fiscal landscape, encompassing Income Tax, Value Added Tax (VAT), all forms of Withholding Taxes, and various levies and duties detailed in the attached Schedule.
Contextualizing the Finance (No. 7) Act, 2024
The aggressive deadlines imposed by SI 81/2025 must be evaluated against the backdrop of the increased tax burden and expanded scope of taxation introduced by its enabling legislation, the Finance (No. 7) Act, 2024 (also referred to as the Finance Act 2024 in some contexts).
The Act significantly increased certain liabilities, thereby raising the stakes for timely compliance. The Corporate Income Tax rate, for instance, was raised from 24% to 25% . The implication of this increase is that when combined with the compressed Quarterly Payment Date (QPD) deadlines stipulated in the SI (detailed in Section IV.A), any failure in accurate quarterly forecasting or delayed submission now carries a greater financial impact on corporate liquidity.
Furthermore, the 2024 Act introduced or amended several key levies that are now subject to the rigorous remittance schedules defined in SI 81/2025:
- Mining and Quarrying Levy: New or revised levies apply to specific minerals. While some sources indicate a 1% levy on gross sales (export or local) for minerals such as lithium, black granite, and quarry stones , other legislative text suggests a 2% levy on the gross value of sale for the same materials, payable in the currency of trade. The remittance of this Levy on Specified Minerals is now strictly due by the 5th day of the following month .
- Intermediated Money Transfer Tax (IMTT): The framework for IMTT continues to be enforced and clarified, including provisions for different rates applied to the transfer of the Zimbabwe gold-backed digital token (ZIG) . The remittance of IMTT is categorized under the highly restrictive 5th-day deadline .
- Presumptive Tax Revisions: The Act revised presumptive tax rates for various categories, including operators of taxis, omnibuses, and butcheries . The submission deadlines for these returns are split: Presumptive Tax Return (Other) is due quarterly (15th day after end of quarter), while Presumptive Tax for Informal Trade is due monthly (5th day of the following month) .
Core Regulatory Shift: The ZiG Mandate and Dual-Currency Compliance
Interpretation of Clause 3: Statutory Equivalence
Clause 3 of SI 81/2025 dictates that “Any reference to the Zimbabwe dollar in any of the revenue acts shall be construed to be reference to the local currency” . This provision is far more than a simple clerical update; it represents a significant legislative maneuver designed to confer stability and legal grounding to the newly introduced Zimbabwe Gold (ZiG or ZWG) currency, which was launched in April 2024 .
By legally defining the old, volatile Zimbabwean dollar (ZWL) reference as simply the “local currency,” the government ensures that tax obligations automatically track the central bank’s monetary decisions. Should future currency reforms occur, the existing tax acts remain legally sound and enforceable, linked to whatever the designated “local currency” is at that time. This legislative action cements the foundation for the mandatory utilization of ZiG in tax compliance and ensures that tax flows are channeled to support the gold-backed unit .
Operationalizing the ZiG (Zimbabwe Gold) Mandate
The introduction of ZiG, backed by US$900 million worth of hard assets , necessitated regulatory support. To integrate ZiG into formal transactions and enhance its utility, the government mandated a proportional split in tax payments between USD and ZiG . SI 81/2025 provides the statutory basis for this mandatory dual-currency reconciliation.
The operational implications for employers and large organizations are profound, particularly concerning Pay As You Earn (PAYE) and Income Tax:
- Dual Tax Tables: Employers must apply two distinct sets of PAYE tax tables for 2025—one denominated in USD and one in ZiG . For instance, the ZiG PAYE bands start with a tax-free threshold of ZWG 33,600 per year, rising progressively to a top marginal rate of 40 percent above ZWG 1,008,000, mirroring the corresponding USD thresholds .
- Segregated Calculation and Reporting: Income tax is determined based on the currency of the employee’s contract . Furthermore, any benefits in kind must be accurately converted for tax purposes using the official auction rate prevailing on the date the benefit arose .
- Split Remittance: Remittance is not consolidated. Employers must ensure that USD liabilities are remitted separately to the Foreign Currency Account at ZIMRA, while ZiG liabilities must be directed to the Domestic Taxes Account.
Liquidity Risk in Dual-Currency Compliance
The simultaneous enforcement of the aggressive 5th-day remittance deadline for numerous tax heads (including PAYE and IMTT) and the mandatory dual-currency reconciliation creates a substantial and concentrated liquidity risk for businesses. Treasury departments are now required to ensure that they possess sufficient, segregated cash balances in both USD and ZiG by the 3rd or 4th day of the month.
The rationale for this timing pressure is evident: late month-end processes risk failing the 5th-day compliance window. If a large corporate entity operates primarily in USD, it must execute timely conversion of necessary funds into ZiG to cover its local currency tax liabilities. Since companies must remit these funds by the 5th, there is minimal margin for seeking favorable official interbank rates or waiting for sufficient ZiG liquidity. Organizations must pre-position their currency holdings, eliminating flexibility in currency management. The failure to correctly calculate, split, and remit the required currency amounts by the 5th day of the month attracts the high non-compliance penalties stipulated in the legislation.
Exhaustive Analysis of New Tax Return Due Dates (The Schedule)
The Schedule of SI 81 of 2025 provides clear, highly regimented deadlines across three primary compliance frequencies: fixed annual dates for provisional taxes, rapid 15-day transactional reporting, and the standardized 5th and 10th-day monthly remittances.
Fixed Annual and Quarterly Income Tax Planning
These fixed deadlines necessitate proactive financial modeling and planning cycles that are distinct from the demands of monthly closings.t is important to note the slight compression for the 4th Quarter Provisional Return, which is due on December 15th, making it earlier than the 20th day applied to the first three QPDs . This requires earlier final-year forecasting during the peak year-end operational period.
Transactional and Ad-Hoc Tax Deadlines
These categories place the responsibility for compliance outside the standard month-end reporting structure, demanding immediate reporting based on transaction events.
- Capital Gains Return and Special Capital Gains Tax Return: Both the standard Capital Gains Return and the Special Capital Gains Tax Return are due Within 15 days after the transaction date (sale date) . This tight 15-day window requires real-time coordination between a company’s sales, legal, and compliance departments to ensure documentation is standardized, valuation is completed, and the return is submitted before the deadline expires.
- Presumptive Tax Return (Other): This quarterly tax obligation is due By the 15th day after the end of the quarter. This applies to prescribed categories of taxpayers under the presumptive tax regime who are not designated as “Informal Trade.”
Standardized Monthly Remittance Deadlines (The 10th Day)
The 10th-day deadline is primarily dedicated to Value Added Tax (VAT) obligations, suggesting a standardized cycle for consumption tax reconciliation.
All categories of VAT returns are now uniformly required to be submitted and remitted by the 10th day of the following month.
The Critical Aggressive Monthly Remittance Deadlines (The 5th Day)
This category represents the single greatest compliance burden imposed by SI 81/2025, due to the volume of distinct tax heads and the minimal processing time afforded . The standardization of over twenty different obligations to the 5th day of the following month is strategically designed by the revenue authority to streamline monitoring and maximize early-month cash flow into government accounts.
The aggregation of such a diverse array of obligations—from payroll to mining royalties and transaction taxes—removes the historical benefit of staggered deadlines (e.g., 10th, 15th, or 20th). For large taxpayers, this mandates combining multiple data streams (payroll processing, banking systems for IMTT, sales records for WHTs and levies) into one hyper-sensitive compliance batch. Effectively, all internal reconciliation and managerial approval processes must be completed within the first two working days of the new month to meet the D+5 submission requirement.
The extensive list of returns and remittances due by the 5th day of the following month includes, but is not limited to:
- Employment and Remuneration Taxes: PAYE, and Return for Remittance of PAYE on Pension Commutation and Pension Lump Sum Payments.
- Financial Transaction and Transfer Taxes: Intermediated Money Transfer Tax (IMTT), and Withholding Tax on Automated Financial Transaction Tax.
- Mining and Extractive Levies: Remittance of Levy on Specified Minerals, and Return for the Remittance of Mining Royalties.
- Withholding Taxes (WHT) on Income: WHT on Residents’ Tax on Interest, WHT on Resident Shareholders’ Tax (Listed/Not Listed), WHT on Fees, WHT on Non-Executive Directors’ Fees, WHT on Property or Insurance Commission Tax, and WHT on Tenders.
- Withholding Taxes (WHT) on Non-Residents: Non-Residents’ Tax on Remittances, Non-Residents’ Tax on Royalties, and WHT on Non-Resident Artistes/Entertainers.
- Capital Gains WHT: Capital Gains Withholding Tax on Marketable Securities, and Withholding Tax on Capital Gains (Immovable property/Intangibles).
- Other Duties and Levies: Book Makers Tax, WHT on gross winnings of Sports Betting Punters, WHT on Demutualisation Levy, Return for the Remittance of Stamp Duty, Presumptive Tax-Informal Trade, and Tobacco Levy.
Strategic Compliance Implications and Risk Assessment
A. Internal Process Acceleration and Resource Allocation
The shift to the 5th-day deadline imposes a fundamental restructuring requirement on the financial operating model of all taxpayers in Zimbabwe. The internal capacity for timely and accurate reporting must increase exponentially.
Treasury and Cash Management: The requirement to remit substantial amounts of PAYE, IMTT, and WHTs, segregated between USD and ZiG, necessitates strategic pre-funding. Treasury departments must move from reactive monthly funding to maintaining a guaranteed tax float, ensuring both segregated currency balances are available for transfer by the 3rd day of the month. This proactive stance is essential to mitigate the immediate liquidity risks associated with the compressed window and currency splitting.
Payroll and HR Integration: Since PAYE is a large component of the 5th-day obligation, payroll processes must be drastically accelerated. Payroll calculation and authorization must be finalized by the 1st or 2nd day of the month. This tight schedule is mandatory to allow sufficient time for the finance team to perform the necessary dual-currency splitting, execute the reconciliation checks, and generate the mandatory P2 returns for submission by the 5th .
Real-Time Transactional Reporting: The 15-day requirement for Capital Gains returns on immovable property and marketable securities requires organizations involved in significant asset transfers to implement automated reporting systems. The compliance obligation must be instantly triggered by the transaction closure date, forcing legal and sales teams to liaise with finance immediately rather than relying on standard end-of-month reconciliations
B. Technological Readiness and System Integration
The regulatory environment created by SI 81/2025 renders legacy accounting and payroll systems obsolete if they cannot handle the prescribed complexities. Technological investment and customization are now non-negotiable compliance requirements.
Critical system overhauls must address the following:
- Dual-Currency Ledgers: Systems must accurately calculate, track, and generate returns based on segregated ledgers for USD and ZiG transactions.
- Separate Tax Tables: The software must integrate and automatically apply the separate USD and ZiG PAYE tax tables for 2025 .
- Real-time Conversions: Automated functions are required for timestamped recording and conversion of benefits in kind (which must be valued at the official auction rate on the date they arise) into the appropriate reporting currency .
- Online Integration: The final output must be compatible with the online submission requirements through the Zimbabwe Revenue Authority’s (ZIMRA) Self Service Portal (SSP)
[11].
C. Risk Mitigation: Penalties and Interest
The high volume of remittances due on the 5th day, combined with the complexities of managing the USD/ZiG currency split, generates significant technical non-compliance risk. The government has signaled a zero-tolerance policy for delayed or incorrect submissions.
The severity of non-compliance mandates a robust risk mitigation strategy. Penalties can reach a staggering 100% of the unpaid amount, compounded monthly with interest . To preempt this exposure, compliance strategy must prioritize system reliability and the establishment of clear internal cut-off dates. For example, implementing strict Service Level Agreements (SLAs) dictating that data input must finalize by D+1 and payment execution must occur by D+3 creates a necessary buffer against the D+5 statutory deadline.
Conclusions and Prescriptive Recommendations
SI 81 of 2025 formalizes an aggressive fiscal policy designed to improve domestic revenue collection efficiency and solidify the role of the local currency (ZiG) within the formal economy. The legislative change fundamentally shifts tax compliance from a mid-month administrative function to an urgent, early-month treasury function, necessitating immediate systemic and procedural overhaul across all affected organizations.
A. Critical Compliance Milestones (2025 Fiscal Year)
The following table summarizes the key submission schedules, highlighting the intense compression of obligations at the beginning of each month.
Monthly Compliance Calendar Summary (Snapshot)
