Question Tag: Anti-Avoidance

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ATAX – Nov 2016 – L3 – Q1 – Taxation of Companies

Discusses tax planning concepts, anti-avoidance measures, tax evasion, double taxation, and non-tax factors influencing investor choices.

Zezee Nigeria Limited was incorporated on September 7, 2012, but did not commence business until July 1, 2013. Based on its Memorandum and Articles of Association, the company was established to carry on distributorship and general contracting.

Extracts from Statements of Profit or Loss and Other Comprehensive Income:

Additional information:

(i) Other Income comprises:

(ii) Administrative expenses include:

(iii) Details of Property, Plant and Equipment are as follows:

(iv) On January 2, 2015, the company bought another Motor
vehicle for N1,800,000

(v) Extracts of the Statements of Financial Position are given below:

You were recently appointed the Tax Consultant to the company. The directors sought your advice on whether or not to exercise the company’s right of election for the relevant years of assessment.
For all the relevant years of assessment, you are required to:
a. Compute the Adjusted Profit/Loss. (9 Marks)
b. Determine the Assessable Profit/Loss and advise the Company on whether or not to exercise its right of election. (6 Marks)
c. Compute the capital allowances. (4½ Marks)
d. Compute the tax liabilities. (10½ Marks)

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AT – July 2023 – L3 – Q2c – Anti-avoidance measures

Explaining the effectiveness of the Transactional Net Margin Method in combating pricing abuse.

Transactional Net Margin Method under transfer pricing has proven useful in combating abuse and manipulation in the invoicing regime in the commercial world.

Required:
What makes the Transactional Net Margin Method very effective?

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AT – March 2023 – L3 – Q2d – Tax administration in Ghana

Discuss the tax implications of a free zone entity exceeding its approved local sales quota.

Koliko Ltd established a free zone entity in Ghana and got approval to sell 20% locally and export the rest from the Minister of Trade. Contrary to the approval, Koliko Ltd decided to export 60% and sell 40% of its produce into the local market.

According to the Board Chairman of the company, this was wrong and that the Ghana Revenue Authority would consider the whole arrangement as artificial since the company departed from the approval by the Ministry of Trade.

Required:
What is the tax implication of the above arrangement?

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AT – Nov 2019 – L3 – Q3a – Anti-avoidance measures

Explain the objectives of Ghana’s Transfer Pricing Regulations and the concept of the arm’s length principle.

The Ghanaian Government, worried by the rising incidence of Transfer Pricing abuses by Multinational and Group Companies, introduced new transfer pricing rules and guidelines through Transfer Pricing Regulations, 2012 (LI 2188).

Required:

i) Explain any FOUR (4) objectives of the transfer pricing regulations of Ghana. (6 marks)

ii) Explain the arm’s length principle. (2 marks)

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ATAX – Nov 2016 – L3 – Q1 – Taxation of Companies

Discusses tax planning concepts, anti-avoidance measures, tax evasion, double taxation, and non-tax factors influencing investor choices.

Zezee Nigeria Limited was incorporated on September 7, 2012, but did not commence business until July 1, 2013. Based on its Memorandum and Articles of Association, the company was established to carry on distributorship and general contracting.

Extracts from Statements of Profit or Loss and Other Comprehensive Income:

Additional information:

(i) Other Income comprises:

(ii) Administrative expenses include:

(iii) Details of Property, Plant and Equipment are as follows:

(iv) On January 2, 2015, the company bought another Motor
vehicle for N1,800,000

(v) Extracts of the Statements of Financial Position are given below:

You were recently appointed the Tax Consultant to the company. The directors sought your advice on whether or not to exercise the company’s right of election for the relevant years of assessment.
For all the relevant years of assessment, you are required to:
a. Compute the Adjusted Profit/Loss. (9 Marks)
b. Determine the Assessable Profit/Loss and advise the Company on whether or not to exercise its right of election. (6 Marks)
c. Compute the capital allowances. (4½ Marks)
d. Compute the tax liabilities. (10½ Marks)

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AT – July 2023 – L3 – Q2c – Anti-avoidance measures

Explaining the effectiveness of the Transactional Net Margin Method in combating pricing abuse.

Transactional Net Margin Method under transfer pricing has proven useful in combating abuse and manipulation in the invoicing regime in the commercial world.

Required:
What makes the Transactional Net Margin Method very effective?

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You're reporting an error for "AT – July 2023 – L3 – Q2c – Anti-avoidance measures"

AT – March 2023 – L3 – Q2d – Tax administration in Ghana

Discuss the tax implications of a free zone entity exceeding its approved local sales quota.

Koliko Ltd established a free zone entity in Ghana and got approval to sell 20% locally and export the rest from the Minister of Trade. Contrary to the approval, Koliko Ltd decided to export 60% and sell 40% of its produce into the local market.

According to the Board Chairman of the company, this was wrong and that the Ghana Revenue Authority would consider the whole arrangement as artificial since the company departed from the approval by the Ministry of Trade.

Required:
What is the tax implication of the above arrangement?

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AT – Nov 2019 – L3 – Q3a – Anti-avoidance measures

Explain the objectives of Ghana’s Transfer Pricing Regulations and the concept of the arm’s length principle.

The Ghanaian Government, worried by the rising incidence of Transfer Pricing abuses by Multinational and Group Companies, introduced new transfer pricing rules and guidelines through Transfer Pricing Regulations, 2012 (LI 2188).

Required:

i) Explain any FOUR (4) objectives of the transfer pricing regulations of Ghana. (6 marks)

ii) Explain the arm’s length principle. (2 marks)

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