Tax Investigations Specialist
I worked in the Multinationals, Large and Complex area in ZIMRA with responsibility for maintaining an active compliance program for those entities engaged in the mining and transport industries in Zimbabwe. Details of my current role are as follows:• Maintenance of an effective enforcement program (i.e. risk assessments/audits) for those entities judged to be underperforming on an industry basis and/or their tax performance does not equate with economic performance. Issues currently subject to examination include entitlement to immediate write off of exploration expenditure, amortisation of intangibles assets (i.e. reserves and resources), mine site improvements and head office cost allocations. Minerals included Platinum, Palladium and Gold. • Lead the team in conducting Transfer Pricing risk reviews and audits to prevent international profit shifting on entities/issues judged to be high risk i.e. issues such as cross border related party sales, intergroup borrowings, head office cost allocation, and intergroup management and service fee payments. Transactions between related party are tested for compliance with the arm’s length principle.• Enforcement action with regard to the Income Tax on Special mining leases. A high risk issue now subject to audit is apportionment of mining expenditure to increase immediately deductible upstream costs– i.e. where part of the expenditures relate to downstream activities, non-taxable projects and excluded expenses.