Delta Pays US$13.7 Million To ZIMRA Amid US$73 Million Tax Dispute

Delta Corporation Limited has paid US$13.7 million to the Zimbabwe Revenue Authority (ZIMRA) under the country’s strict “pay now, argue later” tax regime, even as it disputes additional assessments totalling US$73 million for the period 2019 to 2022.

In its third-quarter trading update, board chairman Todd Moyo confirmed that ZIMRA’s claims include principal tax, penalties, and interest on both value-added tax (VAT) and income tax. Said Moyo:

“The group had paid a total of US$13.7 million as of 30 September 2025 in line with the ‘pay now, argue later’ principle and pre-existing payment plans.

“We believe any revisions to the payment plan will be rational, with due consideration of the financial health of the business and the fact that the principal amounts were fully paid in legal tender at the relevant periods, based on the best available interpretation of the legislation.”

Both the High Court and the Supreme Court upheld ZIMRA’s position, leading Delta Corporation to escalate the matter further.

However, the Constitutional Court declined to hear the appeal, sending the dispute back to Zimbabwe’s fiscal courts.

Despite these setbacks, board chairman Moyo said the company remains hopeful that any revised payment plan will be “reasonable,” noting that the underlying taxes in dispute had already been settled during the affected periods.

He also pointed out that the group holds substantial government treasury bills, which could potentially be used to offset any final liability. Moyo said:

“The Company paid over US$147m in current taxes during the six months ended 30 September 2025 in Zimbabwe, an increase of 19% over the prior year.

“Management continues to engage with ZIMRA while appealing some legal and factual issues of the assessments and the judgments, with guidance from tax experts and legal counsel.”

The size of the tax assessments, coupled with the strict “pay now, argue later” enforcement model, is creating concern across Zimbabwe’s corporate sector.

Investors, local companies, and multinational firms are closely watching how ZIMRA, the courts, and the Treasury resolve the dispute, seeing the outcome as a key indicator of the country’s regulatory predictability.

More: Business Times