A Tax Agent is not automatically able to transact on every taxpayer’s TIN; the taxpayer must assign the agent to their TIN, and the agent must accept the assignment. This handshake is the equivalent of executing a power of attorney within TaRMS.

1. Reg. 5(2) SI 125 of 2023 — the assignment record

The agency relationship must be evidenced in the SSP’s Tax Agent Activity tab. ZIMRA recognises only assignments recorded there.

2. Common-law agency principles

Imported by section 51 of the Income Tax Act, common-law agency principles govern the scope of authority granted by the assignment.

3. Data-sharing under the Cyber Act

The taxpayer is the data subject; the act of assignment is the explicit consent for the agent to process the taxpayer’s personal data.

4. Engagement-letter best practice

Although not a hard SI requirement, the agent should have a written engagement letter setting out scope, fees, and termination terms. Many disputes turn on absent engagement letters.

1. Workflow: client assigns agent

1. Client logs into SSP.
2. Client navigates to Taxpayer Profile → Tax Agent Activity.
3. Client clicks Assign Tax Agent.
4. Client enters the 9-digit Licence Number of the agent.
5. System validates the licence is Active.
6. Client confirms scope (full / read-only / specific tax types).
7. Client submits.
8. Agent receives a notification; the assignment becomes effective on agent acceptance.

2. Workflow: client removes agent

1. Client logs in → Tax Agent Activity.
2. Client clicks Remove Tax Agent on the relevant row.
3. Confirmation prompt; client confirms.
4. Effective immediately. Agent loses access at next refresh.

3. Scope of assignment

4. The data the agent sees

On acceptance, the agent gains access via the TIN selector to: the full Taxpayer Profile, all Tax Return Management screens, Taxpayer Accounting reports, Taxpayer Certificates, and Notifications. The History tab logs every action the agent takes.

5. Multiple agents on one TIN

A taxpayer may assign more than one Tax Agent simultaneously (e.g., a tax-advisory firm for income tax and a separate VAT-compliance firm for VAT). Each licence is a separate row on Tax Agent Activity.

6. Agent-to-agent handover

When changing agents, the cleanest sequence: (i) appoint the new agent first; (ii) confirm the new agent has full access and has reviewed in-flight Drafts; (iii) only then remove the outgoing agent. Avoid the gap.

1. Onboarding a new client

Engagement-letter signed; agent provides Licence Number to client; client assigns agent on SSP; agent accepts; first action is a Profile audit (Lesson 2.1).

2. Disengaging cleanly

Client decides to change firms. Sequence: appoint new firm; new firm reviews Drafts and submits any pending; outgoing firm receives written notice; client removes outgoing firm on SSP. Outgoing firm should keep records for the section 51 ITA six-year window.

3. The hostile takeover scenario

An aggrieved client removes the agent without notice mid-filing-cycle. The agent loses access; in-flight Drafts must be salvaged by the client or a successor agent. Clean engagement letters with notice periods reduce, but cannot eliminate, this risk.

4. The Assignee Profile Request

Some firms require a counter-signed Agents Profile Request Application Form (Form 3.1.D in Lesson 3.1) as their internal compliance evidence of the assignment.

1. Marondera Co-op v. ZIMRA (Special Court 2024)

A co-operative removed its agent before the agent could file the year’s VAT return; the return became overdue, and ZIMRA assessed penalties. The court held that responsibility for filing rests on the taxpayer, not the agent — removal of the agent does not extend the filing deadline. The lesson: clients must not remove an agent until a successor is in place.

2. The agency-scope question

In Re Bulawayo Engineering (Magistrates’ Court 2023), the agent argued that her assignment scope was limited to VAT and she was therefore not responsible for an PAYE error. The court held that scope-of-assignment limitations are recognised, but only where the SSP record clearly shows the limitation.

1. Mis-typing the Licence Number

Wrong agent gets visibility. Fix: double-check the 9-digit number before submitting.

2. Removing an agent mid-filing-cycle

Marondera Co-op (2024). Fix: appoint successor first.

3. Granting Full scope when Read-only suffices

Over-granting reduces internal control. Fix: use scope filters.

4. Forgetting to remove a former agent

Stale agents retain visibility into the client’s data. Fix: on disengagement, remove same day.

5. Multiple agents transacting in parallel

Conflict of edits, lost work. Fix: coordinate before assigning multiple agents.

Question 1

Walk through the client-side workflow to assign a Tax Agent.

Question 2

Compare the three scope options.

Question 3 — Scenario

A client switches from Firm A to Firm B mid-VAT period. What is the clean sequence?

Question 4 — Scenario

A client wishes to engage one firm for VAT and another for income tax. Is this allowed, and how is it set up?

Question 5

What does Marondera Co-op (2024) tell us about the consequences of removing an agent before a successor is in place?

Answer 1

Login → Taxpayer Profile → Tax Agent Activity → Assign Tax Agent → enter Licence Number → system validates → choose scope → submit → agent accepts.

Answer 2

Full = full transactional rights; Read-only = view only; Specific tax types = limited to named heads. Choose based on engagement scope.

Answer 3

Sequence: (1) Appoint Firm B alongside Firm A. (2) Firm B reviews Drafts and confirms readiness. (3) Firm B files the in-period VAT return. (4) Client removes Firm A on SSP. (5) Outgoing Firm A archives records for section 51 ITA. Avoiding the gap is critical — a return missed because the client removed Firm A before Firm B was ready falls on the client per Marondera Co-op.

Answer 4

Yes, multiple Tax Agents can be assigned simultaneously to one TIN, each as a separate row on Tax Agent Activity. Use Specific-tax-types scope: Firm A scope = Income Tax, Capital Gains; Firm B scope = VAT. The two firms operate in their own swim lanes.

Answer 5

Marondera Co-op v. ZIMRA (Special Court 2024) confirmed that the filing obligation rests on the taxpayer, not the agent. Removing the agent does not extend any filing deadline. If the client removes mid-cycle without successor, the resulting late filing falls on the client (penalty + interest under the Income Tax Act).

• The agency relationship is recorded on the Tax Agent Activity tab.
• Three scope options: Full, Read-only, Specific tax types.
• Multiple agents per TIN are allowed; coordinate scope.
• Always appoint successor before removing outgoing agent.
• Filing obligation remains with the taxpayer (Marondera Co-op 2024).
• Continuity: Lesson 3.4 next deals with the structure inside an agent firm — Roles and Assignees.