Zimbabwe Platinum Mines (Private) Limited v Zimbabwe Revenue Authority

Judgment No SC 69/24

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Case Details

Court

Supreme Court

Date

19 July 2024

Citation

Judgment No SC 69/24

Neutral Citation

[2024] ZWSC 69

Judgment No.

SC 69/24

Outcome

unknown

Case Type

Appeal

Bench

Presiding

GWAUNZA DCJ

Author

MUSAKWA JA

Full Bench

GWAUNZA DCJCHIWESHE JAMUSAKWA JA

Areas of Law

Tax LawAdministrative Law

Keywords

Income Tax ActFinance ActMatching PrincipleForeign CurrencyPublic Notices

Key Issues

{"issue_text":"Whether the court a quo erred in finding that s 4A(10) of the Finance Act as read with s 15(2)(a) of the Income Tax Act apportions foreign currency and local currency income in the same ratios as foreign currency and local currency expenditure, thereby matching income and expenditure.","issue_type":"law","dispositive":"yes","related_facts":"The dispute over the 60:40 apportionment ratio for expenses."}

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Facts of the Case

Background

The appellant, a platinum mining company, sought a declaratory order regarding the correct method for calculating its income tax liability in foreign currency. The respondent (ZIMRA) declined the appellant's proposed method and imposed a 60:40 apportionment ratio for expenses based on the currency of income. The High Court dismissed the application, leading to this appeal.

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