The Zimbabwe Revenue Authority (ZIMRA) successfully appealed a High Court ruling, with the Supreme Court siding with it in its refusal to issue a Tax Clearance Certificate (TCC) to Pacific Cigarette Company Ltd. while it owed over $19.5 million in taxes and was under corporate rescue. The court found that the High Court had misdirected itself by compelling ZIMRA to issue the TCC despite Pacific’s $19.2 million in income tax arrears and $330,000 in non-resident tax. ZIMRA had rejected the TCC application in January 2025 because the company had settled current obligations but made no payments toward the arrears.
The Supreme Court ruled that ZIMRA’s refusal was an administrative decision, not an enforcement action, and that tax obligations remain enforceable during corporate rescue. The court also dismissed Pacific’s claim that withholding the TCC violated the moratorium on enforcement actions, noting the company’s corporate rescue plan lacked a proper repayment arrangement for its arrears.
The Supreme Court overturned the High Court’s decision, affirming ZIMRA’s right to enforce its statutory mandate without penalty.
