• ZIMRA has sought owner and tenant information from at least two Harare residential estates
• Tax administration is expected to generate US$217.8 million of Zimbabwe’s 2026 revenue measures
• The next test is whether wider visibility improves filing and remittance without worsening compliance costs

Harare — The Zimbabwe Revenue Authority has requested property-owner and tenant information from homeowners associations at Borrowdale Brooke and Arlington Estate under Section 39 of the Income Tax Act as Government intensifies a 2026 tax administration programme aimed at widening the taxpayer base, improving filing and payment compliance and raising domestic revenue from economic activity already taking place.

The Borrowdale Brooke request emerged in late August and sought property-owner names, tenant names, lease commencement dates and contact details, while Arlington homeowners were advised on 7 September that ZIMRA had formally requested owner names, contact details and tenant information under the same legal provision. The two cases place residential property records inside an enforcement architecture that increasingly draws on information held outside taxpayers’ own returns.

Section 39 gives the Commissioner broad authority to require further information for purposes of administering the Income Tax Act. Subsection 3 extends that power to every person, whether a taxpayer or not, allowing ZIMRA to obtain information concerning another person where it considers the information relevant to administration of the Act. 

The property requests have therefore emerged at a time when Zimbabwe is placing much greater fiscal weight on tax administration itself. Under the 2026 International Monetary Fund Staff-Monitored Program, central government revenue is projected at US$9 billion, equivalent to 16% of gross domestic product, with US$233.9 million expected from new revenue measures. Tax-administration measures account for US$217.8 million of that amount, equivalent to 93.1% of the expected incremental yield, while net tax-policy changes contribute US$16 million. 

That composition changes the economic meaning of the current enforcement drive. Government is relying heavily on identifying taxable activity more effectively, improving registration quality and increasing payment compliance rather than obtaining most of the additional revenue through new headline tax measures.

The International Monetary Fund estimates that US$111.5 million of the expected tax-administration gain will come from measures including rental-income taxation, stronger presumptive-tax enforcement, taxation of electronic commerce, migration from presumptive taxation to self-assessment and value-added tax on imported services. Another US$106.3 million is expected from stronger Zimbabwe Revenue Authority performance through domestic taxes, customs and excise, post-clearance verification, post-clearance audits and registration of new taxpayers and informal-sector traders. 

Property is one of the clearest places where that strategy has been formalised. Treasury said in the 2026 National Budget that significant business activity operating from commercial and non-commercial buildings continued to escape the tax net and that many property owners, managers and tenants remained unregistered. Government consequently strengthened the rental-income framework and required mandatory registration of relevant commercial property owners and managers. 

The resulting presumptive rental-income tax applies to qualifying premises used for trade, business or an occupation and charges 15% of gross rental income as final tax. The framework also requires information about leased properties and tenants, giving property relationships a larger administrative role in establishing the taxpayer universe.

The Borrowdale Brooke and Arlington requests should be kept separate from the 15% commercial rental regime because both estates are residential and the available notices do not establish that ZIMRA is applying that tax to homeowners in either development. Their significance lies in the information model itself, with records linking a property to an owner and occupant providing ZIMRA with another route for establishing who sits behind an identifiable asset and whether further examination is warranted.

This information model is becoming more important because ZIMRA’s own data show that registration alone has not solved the compliance problem. The authority registered 73,619 new taxpayers in 2025, below its target of 100,000, while collections from new registrations reached ZWG618.8 million. Of 1.51 million expected tax returns, only 1.07 million were submitted and 488,478 were filed on time, producing an on-time filing compliance rate of 32.36%. 

Payment performance was weaker. ZIMRA received 867,946 remittances against 1.51 million expected during 2025, producing a remittance rate of 57.49% compared with 75.44% in 2024. Those numbers place the fiscal constraint beyond taxpayer identification because the revenue authority also has to convert identified taxpayers into regular filers and actual payers. 

The International Monetary Fund programme has incorporated that conversion problem directly into its monitoring framework. Zimbabwe is required to monitor and report quarterly on the percentage of newly registered value-added tax and Pay As You Earn taxpayers that subsequently file and pay, placing the quality of the taxpayer register alongside the number of registrations as a fiscal performance measure. 

That gives the Borrowdale Brooke and Arlington cases a wider consequence. A homeowners association can identify ownership and occupancy, an estate agent can hold rental and payment records, a tenant can identify a landlord, while fiscal and licensing systems can identify business activity. The more complete those relationships become in ZIMRA’s records, the easier it becomes to direct compliance resources towards activity that requires verification.

ZIMRA’s 2026–2030 Strategic Plan formally places this approach at the centre of the authority’s next phase. Revenue mobilisation and tax-base expansion are listed as a principal strategic pillar, supported by stronger compliance, data-driven insights and efforts to close revenue leakages. Digital transformation is intended to provide the systems and integrations through which those records can become more useful administratively. 

The authority is targeting a tax-to-gross-domestic-product ratio of 22% by 2030 and has linked that ambition to broader taxpayer coverage, integration of the informal sector and increased use of artificial intelligence and risk-management systems. ZIMRA has also pointed to the large informal share of Zimbabwe’s economy as requiring a different approach to domestic resource mobilisation. 

The economic rationale extends directly into Zimbabwe’s fiscal constraints. The 2026 Staff-Monitored Program identifies domestic revenue mobilisation as the main source of budget financing, while public expenditure is being managed against available revenue to limit the accumulation of new domestic arrears. Stronger tax administration therefore affects Government’s ability to pay suppliers, protect expenditure commitments and maintain fiscal discipline. 

Zimbabwe’s strategy also has regional precedent, with South Africa providing the clearest example of a more mature third-party reporting system. The South African Revenue Service requires banks, financial institutions, insurers, medical schemes, fund administrators, attorneys, estate agents, trusts and other designated entities to submit structured taxpayer information, which is then used to pre-populate returns, verify declarations and identify discrepancies or compliance risks. 

The system has reached sufficient scale for South Africa to auto-assess roughly six million taxpayers a year using third-party data supplied by employers and other institutions. Its September 2026 biannual submission period requires approved providers to submit information for the reporting period to the end of August, giving the tax authority recurring access to independently generated records rather than relying exclusively on taxpayer declarations. 

Zimbabwe has not yet demonstrated that level of structured integration across property and other third-party databases. ZIMRA’s estate requests currently establish information gathering under existing legal powers, while its strategic plan establishes the intended move towards deeper digital integration and data-driven compliance.

Regional rental-tax systems also show that Zimbabwe has chosen a comparatively direct collection model for qualifying business premises. Kenya charges 7.5% of gross qualifying residential rent as final tax and does not allow expenses under that regime. Zimbabwe’s comparable gross-based approach applies a 15% final charge to qualifying business rental, placing a larger tax claim against gross receipts before the landlord accounts for maintenance, management, financing and vacancy costs. 

That structure introduces an investment consequence alongside the compliance objective. A commercial property earning US$100,000 in qualifying annual gross rent incurs US$15,000 of presumptive rental tax regardless of the operating costs attached to the asset. A property with US$20,000 of costs carries the same statutory tax amount as one with US$50,000 of costs, leaving the effective tax burden against underlying property income higher for lower-margin assets.

The interaction matters for landlords, developers and investors because the tax treatment can enter rental pricing, lease negotiations and the return hurdle used when deciding whether additional capital should be committed to property. The effect is likely to vary significantly between high-occupancy, low-cost assets and ageing or heavily financed properties carrying larger maintenance and vacancy expenses.

Tax-base expansion therefore has to achieve two economic outcomes at the same time. Government needs additional revenue from economic activity that currently escapes or underperforms within the tax system, while the compliance architecture needs to remain sufficiently workable for taxpayers to enter and remain inside formal structures.

ZIMRA’s 2025 filing and remittance numbers provide the clearest measure of that challenge. Higher registrations will have limited fiscal value if on-time filing remains near one-third of expected returns or remittance rates continue declining, making active taxpayer conversion a more useful measure than registration totals alone. 

The next 12 to 24 months therefore provide several measurable tests of the strategy. Improvement in on-time filing, recovery in remittance rates, stronger revenue from new registrations, expansion of structured third-party reporting and actual tax-administration proceeds approaching the International Monetary Fund’s US$217.8 million estimate would establish that greater taxpayer visibility is translating into fiscal capacity.

Borrowdale Brooke and Arlington provide a property-level view of that wider transition. Zimbabwe is building a tax-administration model that relies increasingly on relationships already recorded elsewhere in the economy, with the fiscal outcome determined by how effectively ZIMRA converts those records into active taxpayers, recurring payments and additional revenue while maintaining a compliance framework capable of supporting continued formal economic activity.

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