Note: this is the fourth part in a series of posts on Tax and, more specifically, the draft Zimbabwean Income Tax bill. The preceding posts:

Putting the whole residency situation to the side (for about four paragraphs), let’s assume that you’re the Minister of Finance, and you’ve already decided which people will be submitting tax returns. You’ve now got a few more decisions to make, which will form the meat of the next few sections of your Income Tax Act. And those decisions will now move from telling us who will pay tax to what tax they will pay. This is the basic calculation:

Gross Income

less Allowable Deductions

equals Taxable Income

multiplied by Tax Rate

gives you Income Tax Payable

less any Foreign Tax Credits and Rebates

now you have Actual Tax Payable

So if you’re in an economic bind and looking to bring in more taxes, you’ll want to increase Gross Income, decrease Allowable Deductions, and up the Tax Rate. Of course, there are those that call that whole scenario Laffable* – but I’m going to defer that explanation and deal with “Gross Income” in this post.
*Google “the Laffer Curve” for a preview.

Source-Based Taxation

If you go back not so long ago, to a time before the internet, life was fairly simple. There weren’t many large multinational companies. Most of the world was part of an Empire. Swiss Bank Accounts were famous for helping you hide stolen artworks – not for helping you evade tax. And the tax collectors were burly gentlemen with no real appreciation for ledgers and income.

Then World War I came along and changed the geo-political landscape. World War II changed it further. And then the rest of the 19th Century watched the colonies of Asia, Africa and South America turn into former colonies. It was the economic equivalent of continental drift: suddenly, money that had flowed halfway across the world during the Empire days was now being dammed and walled within small autonomous territories.

Here’s a better example: picture the United States breaking up into 50 small countries. Border controls between every state; different currencies emerging; big banks breaking up into 50 national banks; capital controls stopping people moving their money between those bank accounts… But instead of emailing and multinational servers routed via somewhere in Estonia, you need to picture all the communication between these new countries happening via letter, telegraph and steamer.

In practical taxation terms, anything that went on outside a country’s borders… Well that was not really something a government could monitor. And besides, the majority of people would not have had the option of making money elsewhere, except for maybe the traders. And because traders were bringing money back to their homeland, and fuelling local industry, it seemed like rather a good idea to only tax them on their local earnings.

Also – it avoided all kinds of pesky issues like asking a neighbouring country if you could send in a tax collector and let him get a bit physical with the cowardly, unpatriotic so-and-so that’s giving his taxes to another government (theirs).

Which is the definition of Source-Based Taxation: a government gets to tax all income that is made within its borders.

But Times Change

The world today is quite different. You can sit in France and run your Irish online distribution company via skype, email, and the occasional warehouse visit (yes – that warehouse in Malaysia). For goodness sake, you can internet bank. Gone are the days of having to pay a visit in person.

And Tax Authorities the world over have raised their heads and said “You know, maybe we could too…”

Before we knew it, “Residence-Based Taxation” became the fad du jour amongst Finance Ministers, Treasury Secretaries and the odd Chancellor of an Exchequer. Legions of former-Revenue-collectors-turned-tax-consultants started popping up at budget breakfasts with smart powerpoint presentations, toothy smiles and the well-oiled “best practice” line in reference to a flurry of new tax bills.


What is Residency-Based Taxation?

Well – it means that if you’re a tax resident (I refer you to yesterday’s definitional crisis), then you declare your entire worldwide income on the tax return.

Of course, if I ended the story there, that would make it sound like you get taxed twice. You don’t (normally). What happens is that the local Revenue Authority will grant you a tax credit for the tax you’ve already paid. Unfortunately, it means that if, for example, the tax rate in your home country is higher than the foreign country where you made your income, your home country will expect you to pay them the extra.

Also – it’s not just the tax rates that might be different. It’s sometimes the “allowable deductions” as well.

So In Zimbabwe’s New Income Tax Bill…

Zimbabwe is moving from source-based taxation to residency-based taxation. So Zimbabwean tax residents should be declaring their worldwide income, as opposed to just what they earned in Zim.

And then any of the other new Zimbabwean Income Tax Rules will apply to that income.