Question Tag: International Taxation

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  • 15 Marks

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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  • 20 Marks

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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  • 20 Marks

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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  • 15 Marks

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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  • 15 Marks

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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  • 6 Marks

AT – NOV 2021 – L3 – Q2c – International taxation | Business income – Corporate income tax

Advise on tax implications of loan forgiveness between a Korean parent company and its Ghanaian subsidiary.

Yelbateng Ltd is a Korean company and has a subsidiary in Ghana, by the name Yelbateng Ghana Ltd.

The parent company in 2008 gave a loan facility to the subsidiary to support its operations. However, interest on the loan from 2009 to 2019 came to $8,000,000 after applying a thin capitalisation rule in taxation. As a result, the total amount was accrued by Yelbateng Ghana Ltd, as the company did not have money to pay the interest as agreed in the loan contract.

The total amount of the loan was $20 million. In the year 2020, the Board took a decision to relief the subsidiary of the loan obligation, meaning the loan with its interest was not going to be repaid by the subsidiary.

Required:

You have been invited as a final level candidate to advise the company on the tax implication of this arrangement. (6 marks)

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  • 10 Marks

AT – May 2020 – L3 – Q2b – International taxation

Analyze tax implications for an Italian company constructing a fuel depot in Ghana, distinguishing between trading in Ghana and trading with Ghana

XYZ Parks Ltd, an Italian Company, had a contract for the construction of a fuel depot in Ghana. It was clear from the contract agreement that the production and fabrication costing $500,000 would be carried out outside Ghana. The installation works in Ghana and related services would cost $200,000 and GH¢2,400,000 respectively.

XYZ Parks Ltd has asked of your professional advice on the above transaction.

Required:
i) What is the tax implication of trading in Ghana and trading with Ghana? (4 marks)
ii) What will be your professional advice to XYZ Parks Ltd on the tax implication of other contract? (6 marks)

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  • 20 Marks

AT – Dec 2023 – L3 – Q1 – International taxation

Calculating tax adjustments for related party transactions between Abirem Ltd and Gomoa Ltd, including pricing and dividend issues.

Gomoa Ltd, a resident of the United States of America, established two companies, Komenda Ltd (resident in South Africa) and Abirem Ltd (resident in Ghana). The Ghana Revenue Authority (GRA) requested information about Abirem Ltd for tax purposes.

The details for the 2021 year of assessment are as follows:

Additional information:
i) Gomoa Ltd invoiced goods to Abirem Ltd at a price of GH¢1,900,000, which is 10% higher than the market price.
ii) Dividend of GH¢700,000 paid by Abirem Ltd to Gomoa Ltd has been incorporated into Abirem Ltd’s cost.
iii) Management and technical services fee of GH¢1,290,000 paid to the group by Abirem Ltd has been added to operating expenses.
iv) Goods invoiced to Komenda Ltd by Gomoa Ltd amounted to GH¢1,000,000, priced 15% below the arm’s length price.
v) Dividend of GH¢200,000 received by Abirem Ltd from a resident company is included in its revenue. Abirem Ltd holds 25% of the resident company’s voting power.
vi) The Managing Director of Abirem Ltd took goods for personal use, valued at GH¢200,000 (cost), with a margin of 20%.
vii) The Managing Director of Abirem Ltd took additional goods worth GH¢130,000 at cost for home consumption, which was not added to the cost of goods above. The goods were sold at a 10% markup.
viii) Abirem Ltd paid GH¢20,000 in tax in South Africa at a rate of 27% on goods sold, which was included in its revenue.
ix) Abirem Ltd received a loan from Komenda Ltd for operations. Loan details are as follows:

  • Loan amount: GH¢10 million
  • Interest on loan payable: GH¢1,000,000
  • Foreign exchange loss on the loan: GH¢200,000
    x) Equity at the start of the year: GH¢2,000,000, and at the end of the year: GH¢2,800,000
    xi) GH¢400,000 was transferred from retained earnings to share capital.
    xii) Financial gain from derivative: GH¢2.5 million, and financial cost from derivative: GH¢6 million, included in operating expenses.

Required:
Calculate the tax payable by Abirem Ltd for the 2021 year of assessment.

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  • 12 Marks

AT – July 2023 – L3 – Q1a – International taxation

Analyzing the tax implications of share capital, loan interest, revaluation reserves, and thin capitalization

On 1 January 2022, Frost Ltd based in the United States of America acquired 100% shares in Nzungu Ltd in the Gambia. Also, Nzungu Ltd acquired 60% shares in Gyakye Ltd in Ghana.

Frost Ltd granted a loan equivalent of GH¢100 million to Nzungu Ltd. The loan was subsequently passed on to Gyakye Ltd in Ghana to strengthen its capital structure.

The interest equivalent on the loan from Frost Ltd to Nzungu Ltd was GH¢6,000,000. Gyakye Ltd ended up paying GH¢8,000,000 as interest to Nzungu Ltd. The difference in interest payment was a service charge for the role played in transferring the loan to Ghana by Nzunga.

Gyakye Ltd has the following extracts from its Statement of Financial Position as at 2022:

Required:
Evaluate the tax implications of the following:

  1. The movement in the Share Capital.
  2. The loan interest paid.
  3. The movement in the retained earnings.
  4. The movement in the revaluation reserves.
  5. Thin capitalization implications from the above.

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  • 5 Marks

AT – Nov 2019 – L3 – Q2b – International taxation

Explain the benefits that countries A and B stand to gain from a Double Taxation Agreement (DTA).

Countries A and B are contemplating a Double Taxation Agreement (DTA). The two countries are of the view that the Double Taxation Agreement will create a lot of tax benefits to citizens and other persons in both countries. Others have criticized this move as counter-productive and not worth the time of either country.

Your inputs are being solicited as an ICAG Finalist and a patriotic citizen of Country A to provide the benefits to be put on the website of the Ministry of Finance of Country A to enable people to read, appreciate, and support the agreement.

Required:

Explain FIVE (5) benefits that the two countries stand to gain from this arrangement.

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  • 3 Marks

AT – Nov 2019 – L3 – Q2a – International taxation

Outline the conditions required to satisfy before foreign tax credit relief is granted.

Any resident person other than a partnership may be allowed a foreign tax credit relief on any income that is earned outside Ghana subject to the fulfillment of certain conditions, which are critical in the granting of the relief.

Required:

What are the conditions to satisfy before the foreign tax credit relief is granted?

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  • 3 Marks

AT – Nov 2019 – L3 – Q1c – International taxation | Tax administration in Ghana

Explain the tax implications of "Trading in Ghana" versus "Trading with Ghana."

What is the tax implication of the concepts “Trading in Ghana” and “Trading with Ghana” in tax administration arrangement?

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