HARARE — Zimbabwe’s tax authorities are turning to one of the country’s most visible yet historically difficult-to-tax sources of economic activity — property — as the Government moves to close gaps in rental income collection and bring businesses operating from both commercial and residential premises deeper into the formal tax system.
The latest signal came from Borrowdale Brooke, one of Harare’s most affluent residential estates, where the Zimbabwe Revenue Authority (ZIMRA) has requested information on property owners and tenants, including names, lease commencement dates and contact details.
The Borrowdale Brooke Homeowners Association has told residents that it sought external legal advice before concluding that it was legally obliged to comply with the request under Section 39 of the Income Tax Act. The association said it would provide ZIMRA with the information specifically covered by the statutory request and would not disclose information beyond that scope.
On the surface, this is a request for a property register.
Economically, it is considerably more important.
It demonstrates the direction in which Zimbabwean tax administration is moving: away from relying predominantly on taxpayers to identify and declare themselves, towards using third-party information to establish where taxable economic activity exists and who is responsible for it.
The property has become the taxman’s data point
For years, Zimbabwe’s tax system has faced a fundamental visibility problem.
A property may have a landlord. It may have a tenant. It may contain a business. Rent may change hands every month. Employees may work there and customers may buy goods or services there.
Yet none of that necessarily guarantees that the underlying economic activity is visible to the tax authority.
That is the gap Treasury is now attempting to close.
The 2026 Budget proposed mandatory ZIMRA registration for commercial and non-commercial properties where business activities are conducted, together with quarterly submission of tenant registers, occupancy lists and rental schedules by property owners and managers.
The significance of the policy is that it changes the information architecture of taxation.
Instead of asking only, “Who has registered as a taxpayer?”, ZIMRA can increasingly ask, “Who occupies this property, what economic activity takes place there, who owns the property and what income is being generated?”
That is a much more powerful question.
From voluntary disclosure to third-party verification
The Borrowdale Brooke exercise illustrates a broader transformation in tax administration.
A modern revenue authority does not have to depend entirely on a taxpayer voluntarily presenting a complete picture of their economic affairs. It can construct that picture from multiple data sources.
Property records can be matched against taxpayer registration. Tenant registers can be compared with company registrations.
Rental schedules can be compared with declared rental income. Business premises can be compared with presumptive-tax registrations.
Banking information, where legally accessible, can provide another layer of verification. The result is a tax system increasingly built around cross-referencing rather than self-reporting.
That is why the Borrowdale request should not be interpreted simply as a dispute between a homeowners’ association and ZIMRA.
It is a small illustration of a much larger change in the relationship between property and taxation.
Treasury has already laid the groundwork
The policy did not emerge from the Borrowdale Brooke request.
It was foreshadowed in the 2026 Budget.
Treasury argued that significant business activity conducted from commercial and non-commercial buildings continued to escape the tax net, while many property owners, managers and tenants remained outside the formal tax system.
The Government’s response was to make property itself part of the compliance infrastructure.
Under the framework announced in the Budget, property owners and managers would have additional reporting responsibilities, while landlords dealing with informal-sector operators could also acquire withholding obligations.
Where an informal-sector operator liable for presumptive tax fails to comply, the proposed framework requires the property owner or manager to withhold 10% of rental income payable to that operator and remit it to ZIMRA. Non-compliant property owners or managers can face penalties equivalent to the relevant Rental Income Tax and presumptive tax, together with interest. ZIMRA was also given powers to temporarily close premises where required compliance procedures had not been completed. The measures took effect from January 1, 2026.
This is therefore not principally a new tax.
It is an attempt to make an existing tax system more difficult to evade.
The Zimbabwe Financial Mail: a wider formalisation story
The development fits into a broader economic pattern identified by The Zimbabwe Financial Mail, which has argued that Zimbabwe’s unusually large informal economy has effectively created a parallel economic system operating alongside the formal one.
That analysis is important because property sits at the intersection of the two economies. A residential house can become a shop.
A garage can become a workshop. A suburban property can become a private school, medical practice, consultancy or warehouse. A small commercial building can accommodate dozens of informal businesses.
The physical property remains visible. The economic activity taking place inside it may not be.
As The Zimbabwe Financial Mail has observed in its analysis of Zimbabwe’s informal economy, the country’s formal statistics and regulatory systems often struggle to capture activity that is economically real but administratively invisible.
That is precisely the problem the new property-registration framework seeks to attack.
Why landlords are increasingly part of the tax equation
The most consequential aspect of the policy may be that Treasury is no longer treating tax compliance as exclusively the tenant’s responsibility.
The landlord is being brought into the equation. That is a significant development.
If a property owner provides the physical platform from which an informal business operates, the Government increasingly wants that owner to become part of the compliance chain.
This effectively turns landlords and property managers into additional nodes in the tax administration system.
The logic is straightforward.
ZIMRA may struggle to locate every informal trader operating in Zimbabwe’s sprawling commercial ecosystem. It is considerably easier to identify the building in which that trader operates and the person collecting rent from the building.
Property therefore becomes a proxy for economic activity.
And the landlord becomes an information intermediary.
This is where the policy becomes economically interesting
The Government’s strategy reflects a reality that has become increasingly difficult to ignore: Zimbabwe’s informal economy is too large to remain outside the fiscal architecture indefinitely.
But there is a distinction between formalisation and taxation.
If the Government simply uses the property system as another mechanism for collecting taxes, it risks pushing marginal businesses further into informality.
If, however, formalisation gives businesses access to banking, credit, contracts, infrastructure, legal protection and eventually institutional finance, the economics change.
This is the more important policy question.
A trader who becomes tax compliant but gains nothing in return may rationally regard formalisation as an additional cost.
A business that becomes formal, obtains a bank account, establishes a credit history, secures a lease, accesses working capital and becomes eligible for institutional finance has a much stronger economic incentive to participate.
The long-term success of the property tax strategy will therefore depend partly on whether formalisation becomes an economic opportunity rather than simply a compliance obligation.
Property is increasingly becoming financial infrastructure
There is another reason this matters.
Zimbabwe’s property market has become one of the principal repositories of private wealth.
The country’s prolonged monetary instability, currency substitution and limited access to conventional investment instruments have encouraged households and businesses to hold wealth in property.
That has created a property economy extending far beyond traditional residential ownership.
Properties generate rent. They accommodate businesses. They serve as collateral. They preserve wealth. They provide informal employment space.
They increasingly function as quasi-commercial infrastructure.
Once property performs all those functions, it becomes economically rational for the tax authority to make it part of its information architecture.
The Government is effectively saying that economic activity cannot remain invisible simply because it occurs inside a privately owned building.
Borrowdale is symbolic, but the policy is much bigger
The focus on Borrowdale Brooke naturally attracts attention because of the area’s reputation as one of Harare’s wealthiest residential enclaves.
But the economic significance of the policy extends far beyond affluent suburbs.
The same logic can eventually apply to commercial buildings in central business districts, shopping centres, industrial properties, office blocks, mixed-use developments and ordinary residential properties being converted into business premises.
That could materially expand ZIMRA’s ability to map the economy.
The question becomes less about whether a business has voluntarily entered the tax system and more about whether the physical location of that business can be identified.
Once the premises are identified, the taxpayer becomes considerably easier to identify.
Internationally, the principle is hardly unusual
Zimbabwe is not inventing the concept of taxing rental income.
The treatment differs between jurisdictions, but rental income is ordinarily part of the taxable income architecture in many economies.
Botswana, for example, treats the letting and leasing of land and buildings as a business activity for income-tax purposes. Rental receipts form part of taxable income, with specified expenses potentially deductible.
Kenya takes a different approach for residential rental income, applying a 10% tax on gross residential rental income for qualifying taxpayers.
The comparison illustrates an important point.
The debate is not really whether rental income should be taxed.
The harder administrative question is how the tax authority identifies the landlord, establishes the rental relationship and verifies the amount of income being generated.
Zimbabwe’s current reforms are aimed heavily at that administrative problem.
The information revolution is changing tax collection
The significance of the Borrowdale request ultimately lies in data. Tax administration is becoming increasingly information-driven.
A revenue authority with access to reliable property, company, banking, employment and transactional data can identify inconsistencies that would be almost impossible to detect through traditional audits alone.
Suppose, for example, that a property register identifies a building occupied by five businesses.
Company-registration data identifies only two. ZIMRA records identify only one taxpayer. Rental information shows five separate tenants. That discrepancy itself becomes an audit signal.
The authority does not need to begin by accusing anyone of evasion. It simply needs to ask why the datasets do not reconcile.
That is a fundamentally different model of tax enforcement. But there is a danger in enforcement without trust
There is, however, a legitimate policy concern.
The expansion of ZIMRA’s information-gathering powers must be accompanied by clear safeguards around the collection, use and protection of personal information.
The Borrowdale Brooke association’s decision to seek legal advice before responding illustrates precisely why.
Property ownership and tenancy information can contain sensitive personal and commercial data. The legitimacy of the Government’s tax objective does not eliminate the need for disciplined information governance.
Nor should tax enforcement become synonymous with an assumption that every landlord or tenant is non-compliant.
Information gathering is not proof of wrongdoing.
The strength of the system will ultimately depend on whether ZIMRA can distinguish between identifying taxable activity and presuming tax evasion.
The bigger fiscal question
Zimbabwe’s fiscal challenge is ultimately a problem of breadth.
A narrow tax base places an excessive burden on those already inside the formal economy.
Companies that operate transparently, employees whose salaries are taxed at source and formal businesses that maintain complete accounting records carry a disproportionate share of the fiscal burden when large parts of the economy remain outside the tax net.
Broadening the tax base therefore has an economic logic beyond simply raising more revenue. It can make the system fairer.
But that argument works only if enforcement is reasonably even-handed.
If formal businesses are pursued aggressively while politically connected or economically powerful interests remain outside effective scrutiny, tax formalisation can instead reinforce perceptions of inequality.
The credibility of the exercise will therefore depend not only on how much revenue ZIMRA collects, but on whose economic activity it is prepared to see and tax.
Property owners should expect a different operating environment
For landlords and property managers, the direction of travel is now clear. Property records are increasingly becoming tax records.
Lease agreements are becoming potential sources of tax intelligence. Tenant registers are becoming compliance documents. Occupancy schedules are becoming tools through which the tax authority can map economic activity.
The era in which a property could be regarded purely as a private asset, disconnected from the tax consequences of the economic activity conducted within it, is gradually disappearing.
That does not mean every landlord becomes responsible for every tax obligation of every tenant. It does mean the landlord is increasingly part of the compliance architecture. The real test will be what ZIMRA does with the data
The Borrowdale exercise will ultimately be judged not by the number of names collected but by what happens afterwards.
If ZIMRA can use the information to identify previously invisible rental income, bring businesses into registration, improve compliance and broaden the fiscal base, the exercise will have achieved its purpose.
If it simply generates another large database that is poorly integrated with the rest of the tax system, its economic value will be considerably smaller.
The transformation of tax administration requires more than information collection.
It requires information to be reconciled, analysed and converted into intelligent enforcement.
That is where the real institutional challenge begins.
A new relationship between property and the state
The significance of Borrowdale Brooke is therefore not that ZIMRA has suddenly discovered property.
It is that the state is beginning to treat property as a map of economic activity. The building identifies the location. The lease identifies the relationship. The tenant identifies the operator.
The rental schedule identifies the transaction. The tax register identifies the taxpayer.
Put those pieces together and an economic activity that was previously difficult to see becomes considerably harder to hide.
Zimbabwe’s tax authorities are betting that this visibility can translate into revenue.
For landlords, tenants, property managers and businesses, the message is equally clear: the physical economy is becoming part of the digital tax economy.
The property may remain private.
But the income generated from it is increasingly becoming visible to the state.
