No. 1/2019 Finance “12A Taxation of certain income deemed to be from a source within Zimbabwe (1) This section applies to the taxation of income deemed in terms of section 12(6) and (7) to be income from a source within Zimbabwe. (2) Every person who provides services as a satellite broadcasting service, or provides or delivers goods and services as an electronic commerce platform, which receives revenues in excess of five hundred thousand dollars ($500 000,00) in any year of assessment from the provision or delivery of such goods or services to persons resident in Zimbabwe, shall pay tax on such revenues charged and levied at the rate specified in section 14(2)(k) of the Charging Act. (3) Any amount so received or accrued in any year of assessment by way of income arising by virtue of section 12(6) and (7)— (a) shall, notwithstanding section 7, be charged to tax in such manner and at such rates as may be fixed by the charging Act relating to that year of assessment; and (b) shall not reduce any assessed loss which the taxpayer would have had in that year of assessment if such amount had not been received by or accrued to him or her. (4) Sections 19A (“Non-resident companies: basis of charge to and determination of company tax”) and section 19B (“Meaning of “permanent establishment””) shall not apply to the taxation of income deemed to have accrued from a source within Zimbabwe in terms of section 12(6) and (7).”. 7 Amendment of section 15 of Cap. 23:06 With effect from the year of assessment beginning on the 1st January, 2019, section 15 (“Deductions allowed in determination of taxable income”)(2) of the Income Tax Act [Chapter 23:06] is amended in paragraph (f)(i) by the repeal of the proviso thereto and the substitution of— “Provided that an allowance or deduction in terms of this subparagraph may be claimed in respect of two or more mining locations together, whether or not the expenditure or losses are attributable to any one or more mining locations concerned, where the Commissioner is satisfied that the mining operations conducted on the mining locations are inseparable or substantially interdependent, that is to say— (i) both or all of the mining locations are held by the same taxpayer; and (ii) the mineral or minerals produced at the locations are subjected to an integrated process of beneficiation under the control of the taxpayer.”. 8 Amendment of section 16 of Cap. 23:06 Section 16 (“Cases in which no deduction shall be made”) (1) of the Income Tax Act [Chapter 23:06] is amended by the insertion of the following paragraph after paragraph (d)— “(d1) any amount of Intermediated Money Transfer Tax charged in terms of section 22G of this Act;”. 6 2019