Question Tag: International Taxation

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ATAX – May 2017 – L3 – Q4b – International Taxation

Explain the term “Tax Havens”, factors for considering them, and list five countries that are tax havens.

In the words of Benjamin Franklin, “the only things that are certain are death and taxes”. However, in some countries, taxes are not necessarily certain.

Required:
i. Explain briefly the term “Tax Havens”. (4 Marks)
ii. State THREE factors in considering whether a jurisdiction is a Tax Haven. (3 Marks)
iii. State FIVE countries that are Tax Havens. (5 Marks)

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ATAX – May 2019 – L3 – Q5c – Double Taxation Reliefs and Credits

Advise on double taxation relief for SOKGlobal Limited and compute the applicable relief.

SOKGlobal Limited is a wholly owned Nigerian company that deals with stationery items. It has a functional business unit in Cape Town, South Africa. The company’s operating results for the year ended December 31, 2017, are as follows:

Profit attributable to South Africa business: ₦8,740
Capital allowances agreed with tax officials for Nigeria and South Africa businesses were ₦5,500,000 and ₦2,210,000, respectively.

Required:
Advise the company on the double taxation relief applicable to the company, showing the necessary computations.

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ATAX – May 2019 – L3 – Q5a – Double Taxation Reliefs and Credits

State provisions regarding double taxation agreements between Nigeria and another country, as provided in Sections 34 and 35 of the Companies Income Tax Act.

a. State four of the specific provisions of the law as provided in Sections 34 and 35 of the Companies Income Tax Act Cap C2 LFN 2004 (as amended) regarding where there is a double taxation agreement between one country and Nigeria. (2 Marks)

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AT – Nov 2014 – L3 – SC – Q6b – Double Taxation Relief

Provide advice on mitigating double taxation for an individual earning income across multiple countries.

Rev. (Dr.) Smart is an individual who has worked in many countries. Many of his disciples regard him as a “Great man of God” because he has won so many souls and performed real miracles.

He had worked in Ghana, South Africa, Zimbabwe, United Kingdom, Canada, Germany, Netherlands, and the United States of America.

His annual income is earned piecemeal from each country where he ministers. From his itinerary in 2013, as provided by his Personal Assistant, he had visited more than fifteen countries including Nigeria, and in some cases, stayed for more than two months in a few of the countries visited.

He is faced with how to determine his taxable income in each of the countries visited as well as tax payable in Nigeria where he permanently resides.

You have been appointed as the Tax Consultant to Rev. (Dr.) Smart.

Required:
Advise on the relevant provisions of the Tax Laws that will mitigate the possible effect of paying tax on the same income in two or more countries.

(5 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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ATAX – Nov 2021 – L3 – Q5 – International Taxation

Discusses the conditions for significant economic presence and the tax implications for TWITTY Incorporation.

The rapid growth in information and communication technology in Nigeria has brought with it boundless opportunities and changes in the way business activities are conducted. A significant number of transactions in Nigeria, in recent times, are consummated using mobile devices and online payments. In the same vein, the online platforms (mostly operated by international private entities) are perceived by various governments in developing countries (Nigeria inclusive) as undermining the economic interests of their host countries through non-payment of taxes, despite their significant economic presence.

In light of the above, the Finance Act 2019 provides for the treatment of digital and other service providers concerning the significant economic presence of a foreign entity. This provision was followed up with the issuance of Companies Income Tax (Significant Economic Presence) Order 2020 by the Federal Government of Nigeria.

You have been contacted by a foreign online outfit with interest in mobile networking and consultancy, TWITTY Incorporation, California, USA, through its official partner in Nigeria, MAAbioro Partners, to explain issues on the significant economic presence of a foreign entity, deemed to be operating in Nigeria.

Required:

As a tax consultant to TWITTY Incorporation, draft a report explaining the following areas:

a. The objectives of the relevant provisions of Finance Act 2019 and Companies Income Tax (Significant Economic Presence) Order 2020 concerning the significant economic presence of a foreign entity. (3 Marks)
b. Conditions for the determination of significant economic presence for digital activities. (5 Marks)
c. Determination of significant economic presence for technical and consultancy services. (2 Marks)
d. Activities exempted from significant economic presence in Nigeria. (3 Marks)
e. The tax implications of the Order 2020 on the activities of TWITTY Incorporation. (2 Marks)

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AT – Nov 2023 – L1 – SB – Q4 – Double Taxation Reliefs and Credits

Explanation of the Nigerian-UK Double Taxation Agreement provisions, exempted foreign incomes, conflict resolution mechanisms, and tax treaty benefits.

A notable State‟s Chamber of Commerce and Industries has invited you and three
other tax consultants to their quarterly interactive forum, tagged “The Nigerian
Double Taxation Agreement with the UK.” The participants are top private sector
based industrialists who will be visiting the United Kingdom on a trade mission
next week.

Required:

As the lead discussant, you are to prepare a paper explaining the provisions of the Nigerian double taxation agreements with the United Kingdom in respect of:

i. Income arising from immovable properties (2 Marks)
ii. Business profits not arising through a permanent establishment (2 Marks)
iii. Profits or gains arising from the operations of ships and aircraft in international traffic (2 Marks)
iv. Dividends derived by a company resident in one country from a company resident in another country (2 Marks)
v. Interest arising in one country and paid to a resident of the other country (2 Marks)

b. State THREE foreign incomes exempted from Nigerian tax. (3 Marks)

c. Discuss THREE widely recognised resolution mechanisms being used by the Nigerian government to mitigate the effect of the conflicts between double taxation agreements and Nigerian tax laws. (3 Marks)

d. Explain FOUR benefits of double taxation agreements. (4 Marks)

(Total: 20 Marks)

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AT – Nov 2023 – L1 – SB – Q3 – Capital Gains Tax

Evaluate capital gains tax implications and relief for Damaturu Nigeria Ltd on asset disposal and reinvestment under Nigerian tax laws.

a. Explain the provisions of the Capital Gains Tax Act C1 LFN 2004 (as amended) in respect of tax payable on disposal of assets situated outside Nigeria by a non-Nigerian company. (2 Marks)

b. Damaturu Nigeria Limited had been in business as a manufacturer of dairy products for several years. In its bid to re-engineer its operations by investing in another viable product line (to be cited in a major city), the Board of Directors in February 2022, approved the sales and re-acquisition of some assets as shown below:

(i) The underlisted assets were acquired in 2015:

Description N’000
Land 25,000
Plant and equipment 13,000
Factory building 30,000

(ii) Sales proceeds from assets disposed of in July 2022:

Description N’000
Land 32,000
Plant and equipment 15,000
Factory building 38,000

(iii) Expenses incurred (as percentage of sales proceeds) in connection with disposal of assets:

  • Legal: 1%
  • Professional valuers’ fees: 3%

(iv) Re-investment in new assets (for the purpose of the business) to replace the disposed ones, was made between September and October, 2022:

Description N’000
Land 28,000
Plant and equipment 18,000
Factory building 30,000

Required:

i. Compute the capital gains tax payable (if any) for each of the transactions and state the date of payment of the tax due. (14 Marks)

ii. Determine the relief available (if any) on the investment in the new assets. (4 Marks)

(Total: 20 Marks)

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AT – Nov 2022 – L3 – Q6 – Double Taxation Reliefs and Credits

Evaluate whether Singapura PTC Limited, a Singaporean company, qualifies for tax exemption in Nigeria due to the Nigeria-Singapore double taxation agreement (DTA). Outline the benefits available under the DTA to Singaporean residents and identify scenarios where the company would still be liable for tax in Nigeria.

Singapura PTC Limited, a company registered in Singapore, derived various income streams from Nigeria in 2021. Following this, the Nigerian tax office issued an assessment based on the Companies Income Tax Act, prompting Singapura PTC Limited to request an objection. The company claims that, as a Singapore resident, it should not be liable for Nigerian taxes due to the double taxation agreement between Nigeria and Singapore.

Required:

  1. Do you agree with the company, that its residence in Singapore qualifies it for tax exemption in Nigeria?
    (5 Marks)
  2. What are the benefits that may be available to a resident of Singapore under the double taxation agreement between Nigeria and Singapore?
    (5 Marks)
  3. State FIVE circumstances under which a company registered in Singapore will be liable to tax in Nigeria.
    (5 Marks)

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AT – Nov 2017 – L3 – Q6 – Tax Administration and Dispute Resolution

Company on the total tax liabilities

Pategi and Abu are brothers based in Hackettstown, New Jersey, USA. In 2009, they, along with ten other African-Americans, incorporated a telecommunications company named Pategi Telecommunications Limited. The company, headquartered in the USA, has a representative office in Share, Kwara State, Nigeria. In the year ended December 31, 2014, the following transactions were extracted from the company’s records:

  1. Number of Minutes of Telecommunication Transactions:
    • U.S. to other parts of the World: 1,705,000 minutes
    • U.S. to Nigeria: 374,000 minutes
    • Nigeria to U.S.: 426,250 minutes
    • Nigeria to Canada: 550,000 minutes
    • U.S. to Canada through Nigeria: 794,750 minutes
      Total Minutes: 3,850,000 minutes
  2. Worldwide Expenses Incurred (Naira):
    • Refurbishment: N7,150,000
    • Rent: N1,100,000
    • Depreciation: N25,991,563
    • Salaries and Wages: N4,065,188
    • Other Disallowable Expenses: N9,658,000
    • Administrative Expenses: N4,820,750
      Total Expenses: N52,785,501
  3. Telecommunication Charges:
    • Average charge rate per minute: $0.50
    • Applicable exchange rate: N198 to $1.00

Required:
Advise the company on the total tax liabilities for the relevant year of assessment. (Total 15 Marks)

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ATAX – May 2017 – L3 – Q4b – International Taxation

Explain the term “Tax Havens”, factors for considering them, and list five countries that are tax havens.

In the words of Benjamin Franklin, “the only things that are certain are death and taxes”. However, in some countries, taxes are not necessarily certain.

Required:
i. Explain briefly the term “Tax Havens”. (4 Marks)
ii. State THREE factors in considering whether a jurisdiction is a Tax Haven. (3 Marks)
iii. State FIVE countries that are Tax Havens. (5 Marks)

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ATAX – May 2019 – L3 – Q5c – Double Taxation Reliefs and Credits

Advise on double taxation relief for SOKGlobal Limited and compute the applicable relief.

SOKGlobal Limited is a wholly owned Nigerian company that deals with stationery items. It has a functional business unit in Cape Town, South Africa. The company’s operating results for the year ended December 31, 2017, are as follows:

Profit attributable to South Africa business: ₦8,740
Capital allowances agreed with tax officials for Nigeria and South Africa businesses were ₦5,500,000 and ₦2,210,000, respectively.

Required:
Advise the company on the double taxation relief applicable to the company, showing the necessary computations.

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ATAX – May 2019 – L3 – Q5a – Double Taxation Reliefs and Credits

State provisions regarding double taxation agreements between Nigeria and another country, as provided in Sections 34 and 35 of the Companies Income Tax Act.

a. State four of the specific provisions of the law as provided in Sections 34 and 35 of the Companies Income Tax Act Cap C2 LFN 2004 (as amended) regarding where there is a double taxation agreement between one country and Nigeria. (2 Marks)

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AT – Nov 2014 – L3 – SC – Q6b – Double Taxation Relief

Provide advice on mitigating double taxation for an individual earning income across multiple countries.

Rev. (Dr.) Smart is an individual who has worked in many countries. Many of his disciples regard him as a “Great man of God” because he has won so many souls and performed real miracles.

He had worked in Ghana, South Africa, Zimbabwe, United Kingdom, Canada, Germany, Netherlands, and the United States of America.

His annual income is earned piecemeal from each country where he ministers. From his itinerary in 2013, as provided by his Personal Assistant, he had visited more than fifteen countries including Nigeria, and in some cases, stayed for more than two months in a few of the countries visited.

He is faced with how to determine his taxable income in each of the countries visited as well as tax payable in Nigeria where he permanently resides.

You have been appointed as the Tax Consultant to Rev. (Dr.) Smart.

Required:
Advise on the relevant provisions of the Tax Laws that will mitigate the possible effect of paying tax on the same income in two or more countries.

(5 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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ATAX – Nov 2021 – L3 – Q5 – International Taxation

Discusses the conditions for significant economic presence and the tax implications for TWITTY Incorporation.

The rapid growth in information and communication technology in Nigeria has brought with it boundless opportunities and changes in the way business activities are conducted. A significant number of transactions in Nigeria, in recent times, are consummated using mobile devices and online payments. In the same vein, the online platforms (mostly operated by international private entities) are perceived by various governments in developing countries (Nigeria inclusive) as undermining the economic interests of their host countries through non-payment of taxes, despite their significant economic presence.

In light of the above, the Finance Act 2019 provides for the treatment of digital and other service providers concerning the significant economic presence of a foreign entity. This provision was followed up with the issuance of Companies Income Tax (Significant Economic Presence) Order 2020 by the Federal Government of Nigeria.

You have been contacted by a foreign online outfit with interest in mobile networking and consultancy, TWITTY Incorporation, California, USA, through its official partner in Nigeria, MAAbioro Partners, to explain issues on the significant economic presence of a foreign entity, deemed to be operating in Nigeria.

Required:

As a tax consultant to TWITTY Incorporation, draft a report explaining the following areas:

a. The objectives of the relevant provisions of Finance Act 2019 and Companies Income Tax (Significant Economic Presence) Order 2020 concerning the significant economic presence of a foreign entity. (3 Marks)
b. Conditions for the determination of significant economic presence for digital activities. (5 Marks)
c. Determination of significant economic presence for technical and consultancy services. (2 Marks)
d. Activities exempted from significant economic presence in Nigeria. (3 Marks)
e. The tax implications of the Order 2020 on the activities of TWITTY Incorporation. (2 Marks)

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AT – Nov 2023 – L1 – SB – Q4 – Double Taxation Reliefs and Credits

Explanation of the Nigerian-UK Double Taxation Agreement provisions, exempted foreign incomes, conflict resolution mechanisms, and tax treaty benefits.

A notable State‟s Chamber of Commerce and Industries has invited you and three
other tax consultants to their quarterly interactive forum, tagged “The Nigerian
Double Taxation Agreement with the UK.” The participants are top private sector
based industrialists who will be visiting the United Kingdom on a trade mission
next week.

Required:

As the lead discussant, you are to prepare a paper explaining the provisions of the Nigerian double taxation agreements with the United Kingdom in respect of:

i. Income arising from immovable properties (2 Marks)
ii. Business profits not arising through a permanent establishment (2 Marks)
iii. Profits or gains arising from the operations of ships and aircraft in international traffic (2 Marks)
iv. Dividends derived by a company resident in one country from a company resident in another country (2 Marks)
v. Interest arising in one country and paid to a resident of the other country (2 Marks)

b. State THREE foreign incomes exempted from Nigerian tax. (3 Marks)

c. Discuss THREE widely recognised resolution mechanisms being used by the Nigerian government to mitigate the effect of the conflicts between double taxation agreements and Nigerian tax laws. (3 Marks)

d. Explain FOUR benefits of double taxation agreements. (4 Marks)

(Total: 20 Marks)

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AT – Nov 2023 – L1 – SB – Q3 – Capital Gains Tax

Evaluate capital gains tax implications and relief for Damaturu Nigeria Ltd on asset disposal and reinvestment under Nigerian tax laws.

a. Explain the provisions of the Capital Gains Tax Act C1 LFN 2004 (as amended) in respect of tax payable on disposal of assets situated outside Nigeria by a non-Nigerian company. (2 Marks)

b. Damaturu Nigeria Limited had been in business as a manufacturer of dairy products for several years. In its bid to re-engineer its operations by investing in another viable product line (to be cited in a major city), the Board of Directors in February 2022, approved the sales and re-acquisition of some assets as shown below:

(i) The underlisted assets were acquired in 2015:

Description N’000
Land 25,000
Plant and equipment 13,000
Factory building 30,000

(ii) Sales proceeds from assets disposed of in July 2022:

Description N’000
Land 32,000
Plant and equipment 15,000
Factory building 38,000

(iii) Expenses incurred (as percentage of sales proceeds) in connection with disposal of assets:

  • Legal: 1%
  • Professional valuers’ fees: 3%

(iv) Re-investment in new assets (for the purpose of the business) to replace the disposed ones, was made between September and October, 2022:

Description N’000
Land 28,000
Plant and equipment 18,000
Factory building 30,000

Required:

i. Compute the capital gains tax payable (if any) for each of the transactions and state the date of payment of the tax due. (14 Marks)

ii. Determine the relief available (if any) on the investment in the new assets. (4 Marks)

(Total: 20 Marks)

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AT – Nov 2022 – L3 – Q6 – Double Taxation Reliefs and Credits

Evaluate whether Singapura PTC Limited, a Singaporean company, qualifies for tax exemption in Nigeria due to the Nigeria-Singapore double taxation agreement (DTA). Outline the benefits available under the DTA to Singaporean residents and identify scenarios where the company would still be liable for tax in Nigeria.

Singapura PTC Limited, a company registered in Singapore, derived various income streams from Nigeria in 2021. Following this, the Nigerian tax office issued an assessment based on the Companies Income Tax Act, prompting Singapura PTC Limited to request an objection. The company claims that, as a Singapore resident, it should not be liable for Nigerian taxes due to the double taxation agreement between Nigeria and Singapore.

Required:

  1. Do you agree with the company, that its residence in Singapore qualifies it for tax exemption in Nigeria?
    (5 Marks)
  2. What are the benefits that may be available to a resident of Singapore under the double taxation agreement between Nigeria and Singapore?
    (5 Marks)
  3. State FIVE circumstances under which a company registered in Singapore will be liable to tax in Nigeria.
    (5 Marks)

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AT – Nov 2017 – L3 – Q6 – Tax Administration and Dispute Resolution

Company on the total tax liabilities

Pategi and Abu are brothers based in Hackettstown, New Jersey, USA. In 2009, they, along with ten other African-Americans, incorporated a telecommunications company named Pategi Telecommunications Limited. The company, headquartered in the USA, has a representative office in Share, Kwara State, Nigeria. In the year ended December 31, 2014, the following transactions were extracted from the company’s records:

  1. Number of Minutes of Telecommunication Transactions:
    • U.S. to other parts of the World: 1,705,000 minutes
    • U.S. to Nigeria: 374,000 minutes
    • Nigeria to U.S.: 426,250 minutes
    • Nigeria to Canada: 550,000 minutes
    • U.S. to Canada through Nigeria: 794,750 minutes
      Total Minutes: 3,850,000 minutes
  2. Worldwide Expenses Incurred (Naira):
    • Refurbishment: N7,150,000
    • Rent: N1,100,000
    • Depreciation: N25,991,563
    • Salaries and Wages: N4,065,188
    • Other Disallowable Expenses: N9,658,000
    • Administrative Expenses: N4,820,750
      Total Expenses: N52,785,501
  3. Telecommunication Charges:
    • Average charge rate per minute: $0.50
    • Applicable exchange rate: N198 to $1.00

Required:
Advise the company on the total tax liabilities for the relevant year of assessment. (Total 15 Marks)

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