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Revenue and public finance — income tax — non-resident shareholders' tax — deduction of such tax from dividends payable to foreign company — company national of United Kingdom — such tax not payable by local companies — whether requirement by foreign company to pay such tax is discriminatory in terms of art 24 of Double Taxation Agreement between Zimbabwe and United Kingdom
Interpretation of statutes — fiscal statute — interpretation — effect of double taxation agreement on interpretation of Income Tax Act
Enrichment — condictio indebiti — mistake of law — not in itself a bar to recovery of money unduly paid — money paid to Commissioner of Taxes due to mistake of law — money recoverable
Interest — mora — liability of fiscus to pay interest ex mora
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