A recent public notice issued by the Zimbabwe Revenue Authority is drawing renewed attention to the role of trusts in Zimbabwe’s property sector, signalling a shift toward tighter enforcement of existing tax compliance obligations and greater scrutiny of asset ownership structures.

In Public Notice 19 of 2026, released on March 30, the tax authority reminded trusts and trustees of their statutory responsibilities under key legislation, including the Income Tax Act, the Value Added Tax Act, and the Capital Gains Tax Act.

The directive outlines a wide range of compliance requirements, covering tax registration, proper record-keeping, and full declaration of income streams such as rental earnings, business profits, investment income and capital gains.

Although the notice does not introduce new laws, analysts say its timing and tone point to a more assertive enforcement posture, particularly in sectors where trusts are commonly used as ownership vehicles.

Trust structures have long played a central role in Zimbabwe’s real estate market, often utilised for estate planning, asset protection and intergenerational wealth transfer. However, compliance practices across trusts have varied significantly, with some entities maintaining rigorous reporting standards while others have lagged in updating records or declaring income.

By explicitly referencing rental and investment income — both core components of property portfolios — ZIMRA has effectively placed trust-held real estate assets under intensified scrutiny.

“The message is clear: property ownership through a trust does not exist outside the tax system,” said a Harare-based property consultant, noting that trustees are now expected to operate with the same transparency and accountability required of formal business entities.

ZIMRA has set April 30, 2026, as the deadline for trusts to regularise their tax affairs. Trustees are required to submit outstanding returns, correct omissions and settle any unpaid taxes within this window. Those who voluntarily disclose discrepancies may benefit from reduced penalties under the authority’s penalty loading framework.

“ZIMRA urges all Trusts and Trustees to immediately review and regularise their tax affairs by correcting any errors, omissions and non-declarations, by submitting all outstanding returns and settling any taxes due on or before 30 April 2026,” the authority said.

However, the notice also carries a firm warning. ZIMRA has indicated that audits will commence in the second quarter of 2026 targeting non-compliant trusts, with potential consequences including tax assessments, penalties, interest charges and recovery proceedings under the Revenue Authority Act.

Beyond immediate compliance requirements, the move signals a broader structural shift in Zimbabwe’s tax environment toward increased visibility of ownership and income flows, particularly in asset-heavy sectors such as property.

For years, trusts have operated with a degree of opacity, largely due to their private nature and structural complexity. ZIMRA’s renewed enforcement push suggests an attempt to close these gaps and align trust-held assets more closely with national tax reporting standards.

Implications for Investors and Trustees

For property investors and trustees, the development underscores the growing importance of administrative diligence. Industry experts note that the strength of a property portfolio is increasingly tied not only to asset value or location, but also to the compliance integrity of the legal structures holding those assets.

The shift could have ripple effects across the property market. Rising compliance costs, potential backdated tax liabilities and increased reliance on professional advisory services may reshape how trusts are managed. 

At the same time, improved transparency could strengthen confidence in Zimbabwe’s formal real estate sector and broaden the national tax base.