Group Taxation

02/10/2025
  • Combined Operations
    • Zimbabwe does not allow taxation of combined operations where more than one company is involved.
  • Transfer Pricing
    • Legislation effective from 2014, enhanced in 2016, requires businesses with related-party transactions to prepare contemporaneous transfer pricing documentation and file an annual return. Penalties apply for non-compliance.
  • Thin Capitalisation
    • Interest deductibility is limited when the debt-to-equity ratio exceeds 3:1 for subsidiaries and holding companies.
  • Controlled Foreign Companies (CFCs)
    • Zimbabwe does not currently have CFC rules.