ZIMRA Prevails in Supreme Court Appeal Against Pacific Cigarette Company

On February 25, 2026, the Zimbabwe Revenue Authority (ZIMRA) won a significant Supreme Court appeal against Pacific Cigarette Company (Private) Limited. The court ruled that the company was not entitled to a tax clearance certificate (TCC) while owing more than US$19.5 million in taxes and operating under corporate rescue.

The unanimous judgment, delivered in Harare on February 16, 2026, found that the High Court had erred in compelling ZIMRA to issue a TCC to Pacific despite substantial tax arrears and ongoing corporate rescue proceedings. Pacific had been placed under corporate rescue on September 20, 2023, due to financial distress triggered by arrear tax assessments totaling US$19,204,398.35 in income tax and US$330,140.26 in non-resident tax on fees.

After creditors, including ZIMRA, unanimously adopted a corporate rescue plan on April 3, 2024, Pacific applied for a TCC on January 2, 2025. The Supreme Court's decision underscores the importance of tax compliance and the legal obligations of companies under corporate rescue.