I A B Company v Zimbabwe Revenue Authority

Key Issues

• {"issue_text":"Whether the Commissioner was entitled to adjust 2010 tax assessments after 6-year prescription period","issue_type":"procedural","dispositive":"no","related_facts":"2010 assessments amended in 2017, more than 6 years later"}
• {"issue_text":"Whether IAB received management services from IAL during 2010-2015","issue_type":"fact","dispositive":"yes","related_facts":"Pre-determined fees invoiced monthly, no evidence of actual services"}
• {"issue_text":"Whether management fees are deductible under section 15(2)(a)","issue_type":"law","dispositive":"yes","related_facts":"Fees pre-determined without proof of services rendered"}
• {"issue_text":"Whether canteen meals for factory workers constitute gross income under section 8(1)(f)","issue_type":"law","dispositive":"no","related_facts":"Meals provided during 15-minute break away from production line"}
• {"issue_text":"Whether IAB can deduct canteen meal expenditure under section 15(2)(a)","issue_type":"law","dispositive":"no","related_facts":"Meals provided for business continuity in 24/7 operation"}
• {"issue_text":"Whether 30% penalty was appropriate","issue_type":"mixed","dispositive":"no","related_facts":"IAB believed in its interpretation but used improper invoices"}

Background