Judgment No. 23/18 Civil Appeal No. SC 145/15 technical, managerial, administrative or consultative nature save for those that are expressly excluded”. [27] I respectfully associate myself with the views quoted above. As in the Zimasco case, the originating cause of the fees in casu, is entirely in Zimbabwe. The fees and charges in issue are raised by the banks holding the nostro accounts in respect of transactions undertaken by them on behalf of the appellant which issues an instruction on behalf of its clients in Zimbabwe and pays on behalf of those clients using its nostro accounts. These transactions clearly amount to services of a managerial or administrative nature within the meaning of para 1(1) of the 17th Schedule. Regarding the Sunfresh case it would appear that the facts are distinguishable from those in the present matter. However, in so far as it conflicts with the Zimasco decision on the issues discussed above I would consider the Zimasco decision to be the correct exposition of the law. [28] Accordingly, I agree with Mr Magwaliba that all three requirements mentioned by Mr de Bourbon are satisfied. It follows that the appellant, as payer of the fees, was obliged to withhold the non-resident tax and remit such tax to the Commissioner within 30days. Disposition [29] The appeal falls to be dismissed on all three grounds. On the question of costs, it was agreed by the parties that there should be no order as to costs. It is accordingly ordered as follows: The appeal is dismissed. 14