Beverages giant Delta Corporation Limited says disputed tax obligations claimed by the Zimbabwe Revenue Authority (Zimra) are now approaching US$100 million after the tax collector raised fresh assessments worth US$24 million during the group’s financial year ended March 31, 2026.
The dispute, centred on foreign currency Value Added Tax (VAT) apportionment, has intensified scrutiny of Zimbabwe’s multi-currency tax framework amid growing concern among corporates over the interpretation and enforcement of tax regulations.
Legal experts have also questioned whether some aspects of Zimra’s enforcement framework are fully supported by legislation.
“The Zimra foreign currency assessment increased by US$24 million in FY26 to US$97 million; US$18,7 million settled to date under ‘pay now, argue later’,” Delta finance director Alex Makamure said during the presentation of the group’s results for the year ended March 31, 2026 on Wednesday.
“Group remains an exemplary taxpayer — US$306 million total taxes paid in Zimbabwe during FY26, an increase of 37% over prior year, including corporate tax, VAT, excise duty, sugar surtax and PAYE (pay as you earn). The Zimra dispute relates exclusively to historic currency-of-payment apportionment, not ongoing compliance.”
Makamure said the dispute covers the period between 2019 and 2024 and relates to foreign currency apportionment calculations.
“Courts have upheld Zimra’s position that currency-of-payment cannot be offset,” he said.
“No further assessments (are) anticipated on this basis. Group holds US Treasury Bills (fair value US$10,2 million) offered for partial offset.”
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The tax claims come as Delta crossed the US$1 billion revenue mark during the review period, driven by strong demand, improved product mix and firmer pricing.
“The proportion of domestic sales denominated in foreign currency was 94% for the full year, an increase from 80% in the prior year,” Delta chairman Todd Moyo said.
Profit after tax rose nearly 36% to US$151,85 million, while cash and cash equivalents increased 106% to US$56,76 million.
Delta said its Zimbabwean operations continued to benefit from improving sales volumes and revenues, supported by exchange rate stability, slowing inflation and improved availability of key raw materials.
However, the company warned that the disputed tax assessments could materially affect operations if upheld in their current form.
“Management continues to engage with Zimra and the fiscal authorities in pursuit of an amicable resolution, while appealing key legal and factual aspects of the assessments with guidance from tax experts and legal counsel,” Moyo said.
“These assessments have a material impact on the group’s operations if upheld in their current form. Ambiguities in the tax legislation remain pervasive, increasing the risk of further interpretation disputes under the existing tax framework.”
“In addition, Zimra’s quantification approach does not fully reflect the implications of the legislation introducing the Zimbabwe Gold (ZiG) currency in April 2024 and the related conversion framework,” the company said.
The board said it was still unable to determine the likely outcome or timing of the dispute’s resolution.
