Tax & TRA

TRA Penalties and Interest in Tanzania: Late Filing, Late Payment, EFD Receipts and Waivers

Cover: TRA penalties and interest under the Tax Administration Act Cap. 438 R.E. 2023, Part XI sections 86 to 97
Part XI of the Tax Administration Act sets interest, penalties and offences for every tax TRA administers. As at 13 October 2026.
Direct answer

How do TRA penalties and interest work in Tanzania? On the Mainland, the Tax Administration Act, Cap. 438 sets them. Filing or paying late costs the higher of 2.5% of the unpaid tax or TZS 300,000 a month for a company, TZS 100,000 for an individual. Unpaid tax also carries interest at the statutory rate, compounded monthly. Understatement costs 50% to 75% of the shortfall.

This guide sets out TRA penalties section by section in the 2023 revised edition, shows how interest is computed with shilling figures, and explains remission, objection, appeal and the Zanzibar position.

What the law says about TRA penalties and interest

Every tax TRA collects on the Mainland shares one set of consequences for default. They sit in the Tax Administration Act, Cap. 438, not in the Income Tax Act or the VAT Act. The current text is the Revised Edition 2023, published by TRA and by the Office of the Attorney General.

Part XI of that edition is headed "Interest, Penalties and Offences". It has four blocks:

Fixed amounts are stated in currency points. Section 4 lets the Minister set the value by order. The Finance Act 2024 raised one currency point to TZS 20,000 (NEW-02-05), as PwC Tanzania's Finance Act 2024 alert records.

The key definition is in section 3. The "statutory rate" means "the prevailing discount rate determined by the Bank of Tanzania". TRA's own summary on its interest, penalties and offences page follows the same structure.

Who is affected

Which sections changed numbers in the 2023 revised edition?

The 2023 revision renumbered the Act. Most articles, many TRA letters before 2024 and older Zatra notes still cite the 2019 numbers. A wrong number looks right because a real section sits there. We compared the TanzLII consolidation as at 30 November 2019 with the R.E. 2023 arrangement of sections.

SubjectR.E. 2019 sectionR.E. 2023 section
Remission of interest and penaltys.70s.81
Interest for under estimating tax payables.75s.86
Interest for failing to pay taxs.76s.87
Penalty for failing to maintain documentss.77s.88
Penalty for failing to file tax returns.78s.89
Penalty for false or misleading statementss.79s.90
Penalty for aiding and abettings.80s.91
Assessment of interest and penaltiess.81s.92
Offence for failing to comply with tax laws.82s.93
Offence for failing to pay taxs.83s.94
Offence for failing to use fiscal devices.86s.97

So "section 76" in a 2019-era letter means late payment interest. In the 2023 edition, section 76 is the liability of managers of entities. Quote the edition with the number.

How much is the penalty for filing or paying late?

Section 89 covers both failures. A person who fails to file a return, or fails to pay tax, by the due date pays a penalty for each month or part of a month the failure continues. The monthly amount is the higher of two figures (NEW-02-06):

The floor applies even when little or no tax is due. A company that files a nil VAT return two months late still faces TZS 600,000. Our guide to the monthly VAT return lists the due dates that start this clock.

Failing to file an estimate or provisional return is penalised separately from failing to file the final return. A company that skips its statement of estimated tax and then files its final return late can face two penalties. See our note on provisional tax.

Independent summaries agree on the rate. PwC Worldwide Tax Summaries, last reviewed on 9 September 2026, gives the same 2.5% and TZS 300,000 figures for companies.

Records count too. Section 88 adds a penalty for failing to maintain documents: 1 currency point (TZS 20,000) a month for an individual and 10 currency points (TZS 200,000) a month for a body corporate (NEW-02-07).

How is interest on late tax computed?

Section 87 charges interest on tax that remains unpaid after its due date (NEW-02-08). Four rules shape the figure:

  1. Rate. The statutory rate, the Bank of Tanzania discount rate. The fee register records 8.75% for the third quarter of 2026 (NEW-02-09).
  2. Compounding. Interest compounds monthly on the outstanding balance.
  3. No pause for disputes. The consolidated text states that interest is not reduced because a court case or other dispute delayed payment.
  4. Withholding agents bear it. An agent cannot recover from the payee interest it owes for failing to withhold.

The Central Bank Rate is a different figure. On 9 October 2026, the Daily News reported that the Bank of Tanzania held the Central Bank Rate at 6.25% for the fourth quarter. TRA uses the discount rate, not the Central Bank Rate. Confirm the discount rate for October to December 2026 before computing.

A monthly rate is the annual rate divided by twelve. At 8.75%, that is about 0.729% a month. On TZS 10,000,000 unpaid for six months, compound interest is about TZS 445,553. Simple interest would be TZS 437,500.

Section 86 adds a second interest charge for provisional taxpayers (NEW-02-10). It applies where an estimate of income tax is below 80% of the correct tax. Interest runs at the statutory rate, compounded monthly, on the instalments that should have been paid. FB Attorneys (22 February 2026) note that sections 86 and 87 are independent: both can hit the same taxpayer in the same year.

What is the penalty for understating tax or a false statement?

Section 90 penalises a false or misleading statement to a tax officer in a material particular. An omission that makes a statement misleading counts as well. The penalty is a percentage of the tax shortfall (NEW-02-11):

A "statement" is broad. It covers returns, documents handed to an officer, answers to questions and statements made to others that are expected to reach TRA.

Transfer pricing has its own scale in section 90(2)(c) (NEW-02-12). For a profit-making entity the penalty is the greater of 30% of the adjustment or 100% of the tax shortfall. For a loss-making entity it is 30% of the adjusted loss. Clyde & Co (3 July 2025) and Clyde & Co (3 July 2026) describe the Finance Act changes.

TRA's summary page lists "100% of the tax shortfall" next to the knowingly-or-recklessly case. That figure belongs to the transfer pricing rule; the general rate in the Act and the register is 75%.

Aiding, abetting or inducing another person to commit an offence carries a penalty of 100% of the tax shortfall on conviction (s.91).

What happens if a business does not issue an EFD receipt?

Section 44 requires anyone who supplies goods or services, or receives payment for them, to issue a fiscal receipt. A fiscal receipt comes from an approved fiscal device, the Government electronic payment gateway or another system the Commissioner General approves. Our guide to EFD receipt rules explains what the receipt must show.

Failure is a criminal offence under section 97, not an administrative penalty (NEW-02-13). On conviction:

EY (30 July 2024) reports the same 20% and TZS 2,000,000 rule and the TZS 4,000,000 cap. PwC notes the Finance Bill had proposed a much higher cap of 1,000 currency points before Parliament settled on 200.

Buyers are exposed too. A purchaser who fails to demand a fiscal receipt faces 20% of the tax evaded or 2 currency points (TZS 40,000), whichever is greater (NEW-02-14). Our note on who needs an EFD machine covers the turnover trigger of TZS 11 million a year (NEW-02-24).

What if a business never registered for a TIN or VAT?

Section 22, as amended by the Finance Act 2026, requires a person starting employment, business or investment to apply for a TIN within 15 days (NEW-02-17). Registration carries no fee. See our guide to TIN registration in 2026.

VAT registration is due within 30 days of crossing TZS 200 million in 12 months or TZS 100 million in 6 months (F0242). TRA can register a person compulsorily under section 33 of the VAT Act.

Neither the VAT Act nor the Income Tax Act carries its own late registration penalty in the sections we read. The consequences come from the Tax Administration Act:

The fine scale under section 93 is not in the Zatra fee register, so we do not print it here. A court sets it on conviction.

Penalty schedule at a glance

The figures below are from the Zatra fee register at 26 September 2026, checked against the Act and the Finance Acts. Government charges are paid to TRA against a GePG control number. The amount on the control number governs on the day of payment.

DefaultSection (R.E. 2023)AmountRegister ID
Currency point values.4, Second ScheduleTZS 20,000NEW-02-05
Late return or late payments.89Higher of 2.5% of unpaid tax or TZS 100,000 (individual) / TZS 300,000 (body corporate), each month or partNEW-02-06
Failing to keep documentss.88TZS 20,000 (individual) / TZS 200,000 (body corporate) each month or partNEW-02-07
Interest on late taxs.87Statutory rate, compounded monthlyNEW-02-08
Statutory rate, Q3 2026s.38.75%NEW-02-09
Underestimated provisional taxs.86Statutory rate, compounded monthly, where estimate is below 80%NEW-02-10
False or misleading statements.90(2), (3)50% or 75% of shortfall; plus or less 10%NEW-02-11
Transfer pricing adjustments.90(2)(c)Greater of 30% of adjustment or 100% of shortfall; 30% of adjusted lossNEW-02-12
Not issuing a fiscal receipts.97(1), (3)Greater of 20% of value or TZS 2,000,000, capped at TZS 4,000,000; or prison up to 3 years; plus twice tax evadedNEW-02-13
Not demanding a fiscal receipts.97(4)Greater of 20% of tax evaded or TZS 40,000NEW-02-14
Misusing a Framework Agreement exemptions.94AFine of 100% of the tax exempted, and the tax becomes payableNEW-02-15
Offences on TRA's electronic tax systems.42(9)Individual: up to TZS 20,000,000 or 3 years; entity: up to TZS 60,000,000NEW-02-16

Section 92 says each failure is assessed separately, and interest and penalties are added to the tax. Where two laws penalise the same failure, TRA applies the higher one.

Worked example: a late VAT return, a late individual return and an EFD finding

The figures below use the register rates and an 8.75% statutory rate throughout. TRA's system computes the official figure, and the rate may change between quarters.

Case 1, Bahari Logistics Ltd. Its July 2026 VAT return showed net VAT of TZS 10,000,000, due by 20 August 2026 (F0245). It filed and paid on 15 October 2026, which is 2 months or part late.

ItemWorkingTZS
VAT duePer return10,000,000
Section 89 penalty, month 1Higher of 2.5% (250,000) or 15 currency points (300,000)300,000
Section 89 penalty, month 2Same test300,000
Section 87 interest10,000,000 × ((1 + 0.0875/12)² − 1)146,365
Total payable10,746,365

The fixed floor decides the penalty here, because 2.5% of TZS 10,000,000 is below TZS 300,000.

Case 2, an individual landlord. Her final return showed TZS 2,000,000 of tax and was filed and paid three months late. The monthly penalty is the higher of TZS 50,000 or TZS 100,000, so TZS 300,000 for three months. Interest at 8.75% compounded is about TZS 44,070. She pays TZS 2,344,070.

Case 3, an audit adjustment. An audit finds TZS 20,000,000 of income tax understated. If TRA finds no reasonable excuse, the section 90 penalty is TZS 10,000,000. If it finds the statement was made knowingly or recklessly, the penalty is TZS 15,000,000. Interest under section 87 runs on the TZS 20,000,000 from the original due date.

Case 4, an EFD finding. A shop sold goods worth TZS 5,000,000 without receipts. Twenty percent is TZS 1,000,000, so the 100-point floor applies and the fine is TZS 2,000,000. On TZS 30,000,000 of sales, 20% is TZS 6,000,000, but the cap limits the fine to TZS 4,000,000. Twice any VAT evaded is added in both cases.

Can TRA waive penalties and interest?

Yes, within limits. Section 81 allows the Commissioner General to remit the whole or part of any interest or penalty imposed under a tax law where he is satisfied there is good cause. The section has no fixed threshold or percentage.

The Minister no longer has a role. The Finance Act 2021 removed the Minister's power to prescribe eligibility, duration and procedure. The Tax Administration (Remission of Interests and Penalties) Regulations 2020 were then revoked by GN No. 713 of 2021, published by the Ministry of Finance. Dexter Attorneys (25 October 2021) confirm that the power now sits solely with the Commissioner General.

A remission application should be in writing to the Commissioner General and should show:

These elements reflect practice, not a prescribed form. TRA also runs time-limited relief windows from time to time. They are announced by public notice, and none is assumed in this guide.

How do you object to or appeal a penalty assessment?

An assessment of interest and penalties is a tax decision. It can be challenged on the same ladder as any assessment.

  1. Objection to the Commissioner General. File in writing within 30 days of service, with grounds and documents (s.62).
  2. Deposit. The objection is admitted only when the taxpayer pays, within 30 days, the greater of the tax not in dispute or one third of the assessed tax (NEW-02-19). The Commissioner General may waive or reduce this for good reason.
  3. Objection decision. The Commissioner General decides under section 63. An unanswered settlement proposal can become the decision after 30 days.
  4. Tax Revenue Appeals Board. Appeal to TRAB under the Tax Revenue Appeals Act, Cap. 408. Filing fees include TZS 10,000 for a notice of appeal and TZS 100,000 for a statement of appeal (NEW-02-20).
  5. Tax Revenue Appeals Tribunal. Appeal from TRAB to TRAT. A notice of appeal costs TZS 30,000 and a statement of appeal TZS 150,000 (NEW-02-21).
  6. Court of Appeal. On points of law only.

An amicable settlement window of 90 days, extendable by 30, now applies to appeals before TRAB or TRAT (NEW-02-22). Our guide to appealing a TRA assessment covers the appeal deadlines and the deposit in depth.

Objection is often paired with remission. A taxpayer may accept the tax but ask the Commissioner General to remit the penalty, rather than dispute the whole assessment.

How does Zanzibar handle tax penalties?

Section 2 applies the Tax Administration Act to Mainland Tanzania and to Zanzibar, but only "in respect of tax laws which apply to both parts of the United Republic". Income tax is generally treated as a Union tax administered by TRA in Zanzibar too, so the penalties above apply to it.

Zanzibar's own taxes, including Zanzibar VAT, are administered by the Zanzibar Revenue Authority. ZRA replaced the Zanzibar Revenue Board under the Zanzibar Revenue Authority Act, 2022, as Beako Law (7 March 2023) explains. Zanzibar has its own tax administration law and its own penalty and interest rules. We could not read that text this session, so no Zanzibar amounts are stated here.

PointMainland TanzaniaZanzibar
Administering authorityTRATRA for Union taxes; ZRA for Zanzibar taxes
Penalty lawTax Administration Act, Cap. 438 R.E. 2023Cap. 438 for Union taxes; Zanzibar tax administration law for ZRA taxes
VAT18% under Cap. 148 (F0239)15% under Zanzibar VAT law (F0246)
Late filing penaltys.89 (NEW-02-06)Union taxes: s.89. ZRA taxes: confirm with ZRA
Interest rateBoT discount rate, compounded monthlyUnion taxes: same. ZRA taxes: confirm with ZRA
RemissionCommissioner General, s.81Union taxes: TRA. ZRA taxes: confirm with ZRA

Our explainer on Union and non-Union taxes sets out which desk owns which tax, and our note on Zanzibar VAT covers the island rate.

What to do now

  1. Pull the ledger. Download the taxpayer ledger from the TRA portal and list every tax head, period, principal, penalty and interest line.
  2. Check each notice. Match each penalty to its section, the edition cited and the month count, and look for double counting.
  3. Pay the principal first. Interest compounds monthly on principal, so clearing tax stops the largest cost from growing.
  4. Decide object or remit. Dispute the assessment within 30 days if the tax is wrong; ask for remission if the tax is right but there was good cause.
  5. Budget the deposit. Set aside the greater of undisputed tax or one third before lodging an objection.
  6. Fix the cause. Install or repair the EFD or VFD, register for TIN or VAT, and put a filing calendar in place.
  7. Separate Zanzibar. Treat ZRA arrears as a separate file with ZRA's own rules.
  8. Brief an advocate early. Use one for any prosecution, seizure, TRAB appeal or formal legal opinion.

Key dates and deadlines

WhenWhatBasis
Within 15 days of starting businessApply for a TINs.22(1), NEW-02-17
Within 30 days of crossing the thresholdApply for VAT registrationVAT Act s.28, F0242
20th of each monthVAT return and payment for the prior monthF0245
Each month or part after a due dateSection 89 penalty and section 87 interest accrueNEW-02-06, NEW-02-08
Within 30 days of service of an assessmentObject and pay the admission deposits.62, NEW-02-19
7 October 2026BoT holds the Central Bank Rate at 6.25% for October to DecemberMonetary Policy Committee
6 January 2027Next BoT Monetary Policy Committee meeting, as reportedThe Respondent, 9 Oct 2026

The January 2027 date is from The Respondent (9 October 2026). Check the Bank of Tanzania for any rate change after that meeting.

How Zatra helps

Zatra's TRA tax audit and dispute service rebuilds the ledger, tests each penalty and interest line, and prepares objection and remission files. Our tax regulatory compliance team keeps monthly returns on time, and our TIN and VAT registration service closes registration gaps. For a single question, the Senior Advisory Session costs USD 49. Ongoing work sits in the Finance and Tax Control package on our pricing page.

Tax, penalties, interest and TRAB fees are paid to TRA or the Board at the official amount against a GePG control number. These government charges are separate from Zatra's professional fee and are never marked up. Our government fees handbook lists the official figures.

TRA decides assessments and remission, and TRAB and TRAT decide appeals. Zatra prepares and coordinates the file; it does not decide or guarantee any authority's outcome. Representation before TRAB or TRAT, a prosecution, a seizure or a formal legal opinion goes to an advocate on our team.

Sources and status

Accurate as at 13 October 2026. Fees are from the Zatra fee register at 26 September 2026; legal text is from the versions listed below.

Figures to confirm before you act

This article is general information based on official sources available at the date of publication. It is not legal, tax or financial advice. Laws and notices change. Verify with the issuing authority or consult Zatra before acting.

Frequently asked questions

Does a nil return filed late still attract a penalty?

Yes. The section 89 penalty has a fixed floor of TZS 100,000 a month for an individual and TZS 300,000 for a company. It applies even when the return shows no tax, because the floor does not depend on the amount due.

Can a company pay the tax and leave the penalty for later?

It can, and that is usually the better order. Interest compounds on unpaid principal, not on penalties. Paying principal first stops the largest cost growing while a remission request on the penalty is considered.

Can TRA accept a smaller objection deposit?

Yes. Section 62(8) lets the Commissioner General waive the deposit or accept a lesser amount where there are good reasons. Apply in writing with the objection and evidence of cash flow. Until TRA agrees, the standard deposit applies.

Will unpaid penalties block a tax clearance certificate?

Usually yes. TRA checks the full ledger, including penalties and interest, before issuing a clearance. Our tax clearance guide explains the process and how to clear a ledger first.

Does a PAYE error by an employer create penalties too?

Yes. Late or short PAYE remittance attracts section 89 penalties and section 87 interest. A withholding agent cannot recover that interest from employees. Our PAYE guide shows how the monthly figure is computed.

Can a director be pursued for a company's tax penalties?

Section 76 of the 2023 edition makes managers of an entity liable in defined circumstances for tax the entity fails to pay. A director facing a personal demand should brief an advocate before replying.

Do penalties stop once a corporate return is finally filed?

The late filing penalty stops accruing when the return is filed. If tax is still unpaid, the late payment limb and interest continue each month. Our corporate income tax return guide covers the filing timetable.

Does TRA publish the names of offenders?

Section 112 of the 2023 edition is headed "Publication of offenders". We did not read its conditions this session. Assume that an unresolved criminal tax matter can carry a reputational cost as well as a financial one.

Sources & regulators

Verify before filing: Rates, forms and thresholds move by Finance Act, Government Notice and portal revision. Confirm the live schedule on the mandate-holder portal before you budget or submit. Law-firm alerts and Big Four notes are discovery only.

Brief the desk

This Insights page is orientation. TRA tax audit and dispute support is the commercial desk for the same facts. Zatra’s fee stays on its own line, separate from government, bank and regulator charges. Approvals are not guaranteed.

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Disclaimer

This article is informational orientation. It is not legal, tax or investment advice and not a government decision. Tanzanian instruments move by Act, Government Notice, Finance Act and portal revision. If a sentence here disagrees with the live mandate-holder, the mandate-holder wins. Zatra Consultants Limited does not issue licences, permits, tax clearances or approvals, and gives no assurance of any regulatory or banking outcome. Professional fees are published only on /pricing/.

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