Income Tax (Exemption from Income Tax) (Fidelity Gold Refinery (Private) Limited) Notice, 2024
Fidelity Gold Refinery's foreign currency earnings from gold sales are exempted from income tax — but only retrospectively, for 1 January 2019 to 31 December 2020, in a notice gazetted more than three years later.
The Minister of Finance has approved the receipts and accruals of Fidelity Gold Refinery (Private) Limited as exempt from income tax in foreign currency, using the approval power in paragraph 2(j) of the Third Schedule to the Income Tax Act, read with section 4A of the Finance Act [Chapter 23:04].
The exemption is narrow in two ways. First, it applies only to receipts and accruals generated from the sale of gold — not to any other income the refinery earns. Second, it is limited to a two-year window that has already closed: 1 January 2019 to 31 December 2020.
That makes this a backdated instrument. It was gazetted on 12 July 2024 but regularises a tax position for years that were already assessed. Its practical effect is on Fidelity's historic assessments and on ZIMRA's treatment of the foreign currency portion of its gold income for those years, rather than on any current-year liability.
Fidelity Gold Refinery is the state-owned sole buyer and refiner of gold in Zimbabwe, so this concerns the tax position of the gold marketing channel itself rather than of individual miners.
One citation point: the notice refers to "the Income Tax [Chapter 23:06]" where it means the Income Tax Act [Chapter 23:06].
What changed
- Fidelity Gold Refinery's receipts and accruals approved as exempt from income tax in foreign currency
- The exemption covers only income generated from the sale of gold
- The exemption runs for two years, from 1 January 2019 to 31 December 2020, and is therefore retrospective
Who this affects
- Fidelity Gold Refinery (Private) Limited
- ZIMRA assessors handling Fidelity's 2019 and 2020 returns
- tax advisers reconstructing historic gold-sector tax positions
Plain-language summary — not legal advice. Always read the full instrument.