Income Tax (Exemption from Income Tax) (Foreign Government Agencies) Notice, 2024
Five foreign state airlines — Air Malawi, Air Zambia, Mozambique Airlines, Emirates and Kenya Airways — are approved as foreign government agencies exempt from Zimbabwean income tax, replacing the 1997 list.
The Minister of Finance has issued a new list of approved foreign government agencies for income tax exemption purposes, under subparagraph (3)(a) of the Third Schedule to the Income Tax Act [Chapter 23:06].
The Schedule names five agencies and the governments they belong to: Air Malawi (Government of Malawi), Air Zambia (Government of Zambia), Mozambique Airlines (Government of Mozambique), 'Emiratese Airlines' (stated as Government of Dubai) and Kenya Airways PLC (Government of Kenya). The entry for Kenya Airways carries the words 'with effect from 1st January, 2019', so that approval is expressed to be backdated by more than five years.
The notice also repeals the Income Tax (Exemption from Income Tax) (Foreign Government Agencies) Notice, 1997 (No. 1), published in S.I. 285 of 1997, which the new list replaces.
The practical effect is that income earned in Zimbabwe by these state-owned or state-linked carriers falls within the Third Schedule exemption rather than being taxed as ordinary business income. Airlines not on the list are unaffected.
Two textual oddities are worth flagging. 'Emiratese Airlines' is evidently Emirates, and Dubai is an emirate of the United Arab Emirates rather than a separate government. And the '1st January, 2019' effective date is printed against the Kenya Airways row rather than as a commencement clause for the whole notice, so it is not clear on the face of the text whether it governs the notice generally. The notice was published in a Government Gazette Extraordinary of 12 April 2024; its running header misprints the citation as 'S.I. 32 of 2023'.
What changed
- New approved list of foreign government agencies for Third Schedule income tax exemption
- Air Malawi, Air Zambia, Mozambique Airlines, 'Emiratese Airlines' (Government of Dubai) and Kenya Airways PLC approved
- Kenya Airways entry expressed to take effect from 1 January 2019
- Repeals the Income Tax (Exemption from Income Tax) (Foreign Government Agencies) Notice, 1997 (S.I. 285 of 1997)
Who this affects
- Air Malawi, Air Zambia, Mozambique Airlines, Emirates and Kenya Airways
- ZIMRA income tax assessors dealing with foreign carriers
- Tax advisers to airlines operating into Harare and Victoria Falls
- Airlines not on the list, which remain taxable
Plain-language summary — not legal advice. Always read the full instrument.