ZIMRA Tax Claims Against Delta Corporation Hit US$97 Million

Zimbabwe’s biggest brewer, Delta Corporation, says tax assessments from the Zimbabwe Revenue Authority (ZIMRA) have risen to US$97 million in 2026, up from US$73 million in 2025.

The increase is mainly due to extra claims linked to the 2021 tax year.

The dispute is over local currency tax payments Delta made during Zimbabwe’s currency changeover. ZIMRA says some of those payments should have been made in foreign currency.

Delta has already paid a large part of the disputed amount under the “pay now, argue later” rule, but almost US$100 million is still in dispute.

Chief executive Matts Valela warned the tax assessments could seriously affect the company’s operations if they are upheld in their current form.

“ZIMRA’s cumulative assessments against Delta Beverages and Afdis now stand at about US$97m, up from US$73m last year. The additional US$24m relates mainly to the 2021 year of assessment, which remains under review,” Valela said.

“Our view is that the 2021 assessment uses a turnover-ratio method that was not expressly provided for in the law at the time, and on best available interpretations.

“We also believe SI 60 of 2024 should be applied, which could materially change the outcome once amounts already paid are recognised.”

Valela said Delta’s position is that it complied with all tax obligations according to the laws and directives that applied when the payments were made during the currency transition.

“In 2021 and prior years, we paid our taxes in the legal tender of the day, at the rates required by law. Our view is that the principal obligations were settled, and these assessments revalue the liability side without similarly recognising the value already paid,” he said.

“We have already paid US$18.7m under the ‘pay now, argue later’ principle. The assessments are being contested through the courts and through amicable engagement with ZIMRA, and we will continue to pursue both processes constructively.”

Valela said Delta is still talking to ZIMRA and fiscal authorities to try to settle the dispute. At the same time, it is appealing key legal and factual points in the tax assessment with the help of tax experts and lawyers.

He said unclear tax laws allow for different interpretations, which raises the risk of more disputes.

More: Business Times