An extension of time to file income tax returns—a relief provision allowed in response to the coronavirus (COVID-19) pandemic—also applies with regard to the due date for filing the transfer pricing return.
The deadline for taxpayers having a 31 December 2019 year-end to file their income tax returns has been extended to 31 August 2020. Taxpayers with approved year-end dates other than 31 December 2019 are expected to file their income tax returns by the date previously agreed upon by the Zimbabwe Revenue Authority.
The transfer pricing return (ITF12C2) is filed as an attachment to the income tax return (ITF12C). Hence, the postponed deadline affects the due date for filing the transfer pricing return.
Transfer pricing practice notes
The Zimbabwe Revenue Authority has issued transfer pricing guidance, a “transfer pricing practise note” in Public Notice 21 of 2020. These practice notes are to be considered together with the transfer pricing provisions under section 98B, as read with the 35th Schedule of the Income Tax Act [Chapter 23:06].
In general, the transfer pricing practise notes are in line with the transfer pricing guidelines issued by certain organizations including the OECD and the United Nations.
A list of countries that the Zimbabwe Revenue Authority considers to be “beneficial tax jurisdictions” has been released. Taxpayers with transactions with a party located in one of those listed countries must file a transfer pricing return (ITF12C2).
Other tax relief provisions in response to the COVID-19 pandemic include an expedited refund mechanism for value added tax (VAT) refunds and a rebate of customs duty on certain “essential goods” used to combat COVID-19 disease. Read an April 2020 report [PDF 108 KB] prepared by the KPMG member firm in Zimbabwe
For more information, contact a KPMG tax professional in Zimbabwe:
Virginia Mutsago | email@example.com
Masiiwa Kambasha | firstname.lastname@example.org
Robert Kamangira | email@example.com
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