Delta’s US$74 Million Tax Appeal Crushed by Constitutional Court
Delta Corporation has suffered a major legal setback after the Constitutional Court dismissed its appeal in a drawn-out tax dispute with the Zimbabwe Revenue Authority (ZIMRA).
The ruling, delivered on July 10, 2025, upheld previous decisions made by the High and Supreme Courts, confirming that Delta is liable for disputed tax assessments amounting to US$74 million.
The dispute stems from ZIMRA’s demand that certain taxes be paid exclusively in foreign currency.
Delta argued that this position ignored payments made in local currency during the assessment period, which had lost value due to currency depreciation and inflation.
The contested charges include principal tax, penalties, and interest relating to value-added tax (VAT) and income tax for the years 2019 to 2022.
Additional assessments issued in November 2024 increased the total disputed amount, compounding those raised in 2022.
According to The Herald, Delta paid US$9.2 million by December 31, 2024, under the “pay now, argue later” principle, while pursuing legal remedies through ZIMRA’s internal appeals process and the judiciary.
However, the Constitutional Court found that Delta had failed to demonstrate any procedural irregularity or violation of rights that would warrant overturning the lower court’s ruling.
“The application cannot succeed because it is not in the interests of justice for the court to interfere with the final decision of the court a quo,” the bench stated.
The judgment leaves Delta Corporation facing the full US$74 million tax liability, marking a critical financial and legal turning point.
Analysts say the ruling may influence how companies approach tax compliance under Zimbabwe’s multi-currency system, with renewed focus on currency valuation and documentation procedures in future assessments.
