Zimbabwe first introduced transfer pricing provisions into law in 2016 by amending the Income Tax Act [Chapter 23:06] (“Income Tax Act”).
Zinzile Mlambo began her career in practice in a firm in Cape Town where she was in the general litigation department but also participated in winding up deceased estates. Subsequently, she returned to Zimbabwe where she registered as a Legal Practitioner and is currently practicing as a commercial dispute resolution and tax lawyer at Manokore Attorneys.
Zinzile’s clients include suppliers of mining components, financial institutions, mining companies, private equity funds, foreign NGOs, real estate developers and private individuals. Zinzile is notably trained in arbitration, having prepared under a senior advocate and sitting arbitrator in Zimbabwe, and has been involved in a few arbitrations.
Experience has included advising:
- A microfinance institution in a local forum in respect to arbitration proceedings involving a shareholder dispute and claims amounting to USD500,000
- A financial institution in an arbitration at AFSA in conjunction with South African counsel in which we successfully represented and defended claims amounting to approximately USD5 million
- A commercial entity, on a potential upcoming arbitration at AFSA involving a claim of approximately USD18 million
- A property developer in a USD12 million land ownership dispute
- A local property developer in a suit against a municipality regarding the application of the local laws regarding property development
- A local and foreign company against a mining conglomerate
- Offshore lenders in recovering funds advanced in terms of facility agreements to local entities
- A foreign multinational which was considering entering Zimbabwe on the tax liabilities of directors and public officers
- Foreign and local potential investors in conducting due diligence exercises on the tax affairs of the entities
- A National Project Status in applications and a Special Economic Zone application
- Registered Legal Practitioner of the High Court of Zimbabwe (2018)
- University of Cape Town, South Africa, LLB (2013)
- University of Cape Town / Law Society of South Africa (“LSSA”) Legal Education and Development, Practical Legal Training (2013)
- 2018 – date, Associate at Manokore Attorneys; DLA Piper Africa member firm in Zimbabwe
- Sept. 2016 – Nov. 2017, Pupil to a Senior Advocate specializing in commercial and tax
- July 2016 – Sept. 2016, Volunteer, Zimbabwean NGO
- April 2014 – July 2016, Candidate Attorney / Legal Consultant, Cape Town based law firm
- Law Society of Zimbabwe (2018 – present)
- Institute of Certified Tax Accountants Student Membership (2018 – present)
We often read from the press that the Zimbabwe Revenue Authority (“ZIMRA”) has “garnished” a person’s bank account. This article explains what it means for a bank account to be garnished and under what circumstances ZIMRA does this.
A company is considered a “person” for tax purposes. Accordingly, the company incurs its own tax liability and is responsible for settling the liability.
Investors who are considering entering the Zimbabwean market inevitably raise the question of the tax implications of their proposed transaction.
Understanding Zimbabwe's relatively new transfer pricing laws is crucial to foreign investors in Zimbabwe, foreign businesses in the country, and Zimbabwean organizations doing business with offshore entities.