In July 2025 Regina Chinamasa, Commissioner General of the Zimbabwe Revenue Authority, went to Paris and signed the Convention on Mutual Administrative Assistance in Tax Matters, making Zimbabwe the 151st jurisdiction to join. Zimbabwe ratified it on 31 August 2026, and from 1 December 2026 ZIMRA can ask 150 other tax authorities, South Africa’s and Mauritius’s among them, for information about its taxpayers.
If you are Zimbabwean tax resident and your savings are in a bank in Sandton or Ebène, read on. If you have been nodding along every time someone says “CRS”, this is your chance to get up to speed.
Firstly, what is CRS?
The Common Reporting Standard is basically the OECD’s rulebook for banks to report on their customers to the tax authority of the country where each customer is tax resident. In short, your bank fills in a form about you every year and the tax authority sends it to the “right” place.
In a little more detail, banks, custodians, certain investment entities and certain insurers in each participating jurisdiction:
- ask every account holder where they are tax resident, which is the self-certification form at account opening that everyone signs and nobody reads;
- where the account holder is a company or trust that mainly holds investments, identify the individuals who control it, which for a trust means the founder, the trustees, any protector and the beneficiaries;
- report each year to their own tax authority the account holder’s name, address, tax number, date of birth, account number, year-end balance, and the interest, dividends and sale proceeds paid into the account; and
- that tax authority sends the report to the tax authority of the jurisdiction where the account holder is tax resident.
South Africa has exchanged information under the CRS since 2017 and Mauritius since 2018. If you have wondered why your bank keeps asking where you are tax resident, this is why.
So will ZIMRA receive a CRS report on my account next year?
Not yet. The CRS needs a treaty to operate under, and for most jurisdictions that treaty is this Convention, which the OECD calls “the primary instrument for the swift implementation” of the CRS. The Convention is the first step, but it does not start automatic reporting on its own. Article 6 provides that Parties exchange information automatically “in accordance with procedures which they shall determine by mutual agreement”, and for the CRS that agreement is a separate one, the Multilateral Competent Authority Agreement.
The OECD’s table of activated CRS exchange relationships, last updated on 25 September 2026, does not include Zimbabwe. South African and Mauritian banks will therefore continue to collect self-certifications from Zimbabwean tax residents and report them to SARS and the Mauritius Revenue Authority, but that information will not be sent yet to ZIMRA under the CRS.
Then what changes on 1 December 2026?
Well it’ll be a happy Christmas for some as on 1 December this year, ZIMRA will gain the right to ask. Until now ZIMRA could request information only from countries with which Zimbabwe has a bilateral tax treaty. From 1 December 2026 it can make a request to any of the 150 other jurisdictions under the Convention, covering income tax, capital gains tax, estate duty and VAT.
The timing has a catch. Under Article 28(6) the Convention applies to taxable periods beginning on or after 1 January 2027. But under Article 28(7), where ZIMRA is investigating intentional conduct that could lead to criminal prosecution, the Convention applies to earlier years as well, from 1 December 2026.
The part most people skip is Article 11, under which one tax authority can ask another to collect its tax for it. Zimbabwe made no reservations when it ratified, so it has signed up to the Convention in full, subject to whatever reservations the other jurisdiction has made.
Who should pay attention
Zimbabwean tax residents with bank or investment accounts in South Africa or Mauritius should definitely start thinking about this. The banks already report those accounts to SARS and the Mauritius Revenue Authority every year. From 1 December 2026 ZIMRA can ask for that information for 2027 onwards, and for earlier years where it is investigating criminal conduct. Where income from those accounts has not been declared in Zimbabwe, the position should be considered now rather than once a request has been made.
Mauritian companies, and South African or Mauritian trusts, with Zimbabwean tax resident shareholders, founders or beneficiaries should also plan. The CRS reports the individuals who control a company or trust that mainly holds investments, so putting a company or trust between the individual and the account does not keep that individual out of the report.
South African tax residents with assets in Zimbabwe also need to think about this, because the exchange works in both directions and SARS has the same right to ask ZIMRA.
The information has been reported to SARS and the Mauritius Revenue Authority every year. What has changed is that ZIMRA will soon be able to ask for it too.
This is general commentary and not advice. Sources: the OECD announcement of 31 July 2025; the Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol; the OECD status table for the Convention as at 1 September 2026; the Council of Europe Treaty Office record of Zimbabwe’s declarations; and the OECD table of activated CRS exchange relationships as at 25 September 2026.
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