Question Tag: Double taxation relief

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AT – Nov 2014 – L3 – SC – Q6a – Double Taxation Reliefs and Credits

Identify double taxation relief and compute the tax liability for a Nigerian company with foreign operations.

Sunproof International Inc. has been in the tyre manufacturing business in Nigeria and Sierra Leone for over ten years.

The Company’s operating results for the year ended 31 December 2012 were as follows:

Particulars N
Income from Nigeria 75,000,000
Income from Sierra Leone 33,000,000
Overheads 60,000,000
Depreciation – Nigeria 6,750,000
Depreciation – Sierra Leone 1,125,000
Donations to Island Club 375,000
Foreign tax suffered 6,300,000

Other information:

  1. Net profit attributable to the Company in Sierra Leone was N7,725,000.
  2. Capital allowances agreed with Tax Officials for operations in Nigeria and Sierra Leone were N5,310,000 and N2,175,000 respectively.
  3. Assume the Company is a wholly Nigerian company.

Required:
i. Identify the Double Taxation Relief available to the Company. (4 Marks)
ii. Compute the tax liability of the Company for the relevant Year of Assessment.

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AT – May 2024 – L3 – SB – Q3 – Double Taxation Reliefs and Credits

Calculation of double taxation relief and tax liabilities for Lagode Nigeria, including implications of double taxation treaties.

Lagode Nigeria Limited, based in Lagos, Nigeria, commenced operations as a manufacturer of indigenous fabrics in 2013. Products are sold to wholesalers and retailers in Nigeria and to Africans in diaspora, particularly during annual holiday periods. A market survey in 2018 revealed a lack of local Nigerian fabric manufacturers in North America, prompting the company to establish Kuramo Incorp. in Ottawa, Canada, which began operations in January 2020.

The operating results for both locations for the year ended December 31, 2022, are as follows:

Description Lagos, Nigeria (N’000) Ottawa, Canada (N’000)
Gross turnover 180,200 330,800
Less: Expenses
– Cost of materials 72,100 162,320
– Wages and salaries 18,050 42,120
– Finance costs 1,400 3,150
– Miscellaneous 4,600 5,270
– Depreciation 5,760 8,750
– Share of head office expenses 25,600 16,040
– Foreign tax paid 18,900
Total expenses 127,510 256,550
Net profit 52,690 74,250

Additional Information:

  1. Ottawa branch is a wholly owned Nigerian company.
  2. Miscellaneous expenses are allowable for tax purposes.
  3. Capital allowances agreed with Nigerian tax authorities:
    Location Capital Allowance (N’000)
    Lagos operations 6,800
    Ottawa operations 9,900
  4. The exchange rate for Canadian operations is fair.
  5. No double taxation agreement exists between Nigeria and Canada.

Required:
In accordance with the provisions of the Companies Income Tax Act Cap. C21 LFN 2004 (as amended), you are to: a. Compute the double taxation relief (if any) available to the Nigerian company

(9 Marks)
b. Advise on the tax liabilities of the Nigerian company for the relevant assessment year (9 Marks)
c. Comment on the implications of double taxation agreements on withholding tax deductions by a company resident in a country:
(i) With no double taxation agreement with Nigeria

(1 Mark)
(ii) With double taxation treaty with Nigeria (1 Mark)
Total: 20 Marks

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AT – May 2018 – L3 – SB – Q4b – Double Taxation Reliefs and Credits

Calculate the final tax liability for Oduifa Construction Ltd., considering foreign income and double taxation relief.

Engineer Kole Ahmed manages a wholly owned Nigerian engineering outfit – Oduifa Construction Company Limited, based at Ikeja and incorporated in February 2010.

Given the challenging economic environment in Nigeria and inconsistent government policies, the company’s management embarked on foreign diversification of income. They sourced and secured some contracts in the United Kingdom where they have operational activities in London.

Extracts from the Statement of Profit or Loss for the year ended December 31, 2015, for Lagos and London operations, are as follows:

Description Lagos (N) London (N) Global (N)
Revenue 68,000,000 70,200,000 138,200,000
Direct expenses (43,410,000) (44,050,000) (87,460,000)
Gross profit 24,590,000 26,150,000 50,740,000
Administrative expenses:
– Staff salaries 1,200,000 1,440,000 2,640,000
– Rent and rates 840,000 960,000 1,800,000
– Motor vehicle expenses 136,000 148,000 284,000
– Repairs and maintenance 92,000 106,500 198,500
– Utilities 76,840 81,000 157,840
– Business insurances 55,000 60,000 115,000

Capital allowances: N725,000.

Required: Compute the final tax liability of the company for the relevant assessment year. (15 Marks)

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AT – March 2023 – L3 – Q1b – Business income – Corporate income tax

Compute the tax payable by Manpower Ltd, considering foreign income and capital allowances.

Kofi Agyemang worked in Canada for a very long time and relocated to Ghana to benefit from the One District One Factory (1D1F) initiative. Kofi Agyemang set up a company called Manpower Ltd and was granted approval by the 1D1F Secretariat to operate a manufacturing company at Koforidua, the capital town of Eastern Region.

An extract from the accounts of Manpower Ltd for the 2021 year of assessment was as follows:

Description GH¢
Chargeable Income 2,000,000
Dividend from Val Ltd:
Ghana (gross) 100,000
Canada (net of tax) 120,000
Interest on current account from:
Ghana (gross) 80,000
Canada (net of taxes) 100,000
Rental Income:
Ghana (gross) 200,000
Canada (gross) 150,000
Depreciation 67,000

Additional information:
i) Taxes paid on the foreign income:

  • Dividend: GH¢18,000
  • Interest: GH¢15,000
  • Rental income: GH¢15,000

ii) Capital allowance agreed with the Ghana Revenue Authority amounted to GH¢140,000.

Required:
Compute the tax payable by Manpower Ltd for the 2021 year of assessment. (8 marks)

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AT – Nov 2014 – L3 – SC – Q6a – Double Taxation Reliefs and Credits

Identify double taxation relief and compute the tax liability for a Nigerian company with foreign operations.

Sunproof International Inc. has been in the tyre manufacturing business in Nigeria and Sierra Leone for over ten years.

The Company’s operating results for the year ended 31 December 2012 were as follows:

Particulars N
Income from Nigeria 75,000,000
Income from Sierra Leone 33,000,000
Overheads 60,000,000
Depreciation – Nigeria 6,750,000
Depreciation – Sierra Leone 1,125,000
Donations to Island Club 375,000
Foreign tax suffered 6,300,000

Other information:

  1. Net profit attributable to the Company in Sierra Leone was N7,725,000.
  2. Capital allowances agreed with Tax Officials for operations in Nigeria and Sierra Leone were N5,310,000 and N2,175,000 respectively.
  3. Assume the Company is a wholly Nigerian company.

Required:
i. Identify the Double Taxation Relief available to the Company. (4 Marks)
ii. Compute the tax liability of the Company for the relevant Year of Assessment.

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AT – May 2024 – L3 – SB – Q3 – Double Taxation Reliefs and Credits

Calculation of double taxation relief and tax liabilities for Lagode Nigeria, including implications of double taxation treaties.

Lagode Nigeria Limited, based in Lagos, Nigeria, commenced operations as a manufacturer of indigenous fabrics in 2013. Products are sold to wholesalers and retailers in Nigeria and to Africans in diaspora, particularly during annual holiday periods. A market survey in 2018 revealed a lack of local Nigerian fabric manufacturers in North America, prompting the company to establish Kuramo Incorp. in Ottawa, Canada, which began operations in January 2020.

The operating results for both locations for the year ended December 31, 2022, are as follows:

Description Lagos, Nigeria (N’000) Ottawa, Canada (N’000)
Gross turnover 180,200 330,800
Less: Expenses
– Cost of materials 72,100 162,320
– Wages and salaries 18,050 42,120
– Finance costs 1,400 3,150
– Miscellaneous 4,600 5,270
– Depreciation 5,760 8,750
– Share of head office expenses 25,600 16,040
– Foreign tax paid 18,900
Total expenses 127,510 256,550
Net profit 52,690 74,250

Additional Information:

  1. Ottawa branch is a wholly owned Nigerian company.
  2. Miscellaneous expenses are allowable for tax purposes.
  3. Capital allowances agreed with Nigerian tax authorities:
    Location Capital Allowance (N’000)
    Lagos operations 6,800
    Ottawa operations 9,900
  4. The exchange rate for Canadian operations is fair.
  5. No double taxation agreement exists between Nigeria and Canada.

Required:
In accordance with the provisions of the Companies Income Tax Act Cap. C21 LFN 2004 (as amended), you are to: a. Compute the double taxation relief (if any) available to the Nigerian company

(9 Marks)
b. Advise on the tax liabilities of the Nigerian company for the relevant assessment year (9 Marks)
c. Comment on the implications of double taxation agreements on withholding tax deductions by a company resident in a country:
(i) With no double taxation agreement with Nigeria

(1 Mark)
(ii) With double taxation treaty with Nigeria (1 Mark)
Total: 20 Marks

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AT – May 2018 – L3 – SB – Q4b – Double Taxation Reliefs and Credits

Calculate the final tax liability for Oduifa Construction Ltd., considering foreign income and double taxation relief.

Engineer Kole Ahmed manages a wholly owned Nigerian engineering outfit – Oduifa Construction Company Limited, based at Ikeja and incorporated in February 2010.

Given the challenging economic environment in Nigeria and inconsistent government policies, the company’s management embarked on foreign diversification of income. They sourced and secured some contracts in the United Kingdom where they have operational activities in London.

Extracts from the Statement of Profit or Loss for the year ended December 31, 2015, for Lagos and London operations, are as follows:

Description Lagos (N) London (N) Global (N)
Revenue 68,000,000 70,200,000 138,200,000
Direct expenses (43,410,000) (44,050,000) (87,460,000)
Gross profit 24,590,000 26,150,000 50,740,000
Administrative expenses:
– Staff salaries 1,200,000 1,440,000 2,640,000
– Rent and rates 840,000 960,000 1,800,000
– Motor vehicle expenses 136,000 148,000 284,000
– Repairs and maintenance 92,000 106,500 198,500
– Utilities 76,840 81,000 157,840
– Business insurances 55,000 60,000 115,000

Capital allowances: N725,000.

Required: Compute the final tax liability of the company for the relevant assessment year. (15 Marks)

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AT – March 2023 – L3 – Q1b – Business income – Corporate income tax

Compute the tax payable by Manpower Ltd, considering foreign income and capital allowances.

Kofi Agyemang worked in Canada for a very long time and relocated to Ghana to benefit from the One District One Factory (1D1F) initiative. Kofi Agyemang set up a company called Manpower Ltd and was granted approval by the 1D1F Secretariat to operate a manufacturing company at Koforidua, the capital town of Eastern Region.

An extract from the accounts of Manpower Ltd for the 2021 year of assessment was as follows:

Description GH¢
Chargeable Income 2,000,000
Dividend from Val Ltd:
Ghana (gross) 100,000
Canada (net of tax) 120,000
Interest on current account from:
Ghana (gross) 80,000
Canada (net of taxes) 100,000
Rental Income:
Ghana (gross) 200,000
Canada (gross) 150,000
Depreciation 67,000

Additional information:
i) Taxes paid on the foreign income:

  • Dividend: GH¢18,000
  • Interest: GH¢15,000
  • Rental income: GH¢15,000

ii) Capital allowance agreed with the Ghana Revenue Authority amounted to GH¢140,000.

Required:
Compute the tax payable by Manpower Ltd for the 2021 year of assessment. (8 marks)

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