Falcon Gold Zimbabwe Limited v Taxing Officer N.O. and Rio Gold (Private) Limited

Key Issues

• {"issue_text":"Whether the taxing officer erred in applying the interbank rate prevailing on invoice dates rather than the date of payment for USD-denominated disbursements","issue_type":"mixed","dispositive":"yes","related_facts":"USD disbursements paid on 4 November 2021 and 23 November 2021; taxation on 1 August 2023"}
• {"issue_text":"Whether S.I. 85/2020 and S.I. 185/2020 changed the currency of account from RTGS to USD for taxation purposes","issue_type":"law","dispositive":"yes","related_facts":"Applicant paid counsel in USD; bill of costs denominated in USD"}
• {"issue_text":"Whether the principle of currency nominalism applies to the taxation of costs in this context","issue_type":"law","dispositive":"yes","related_facts":"RTGS dollar depreciation; applicant sought future interbank rate"}

Background