- 5 Marks
AT – Nov 2014 – L3 – SC – Q6b – Double Taxation Relief
Provide advice on mitigating double taxation for an individual earning income across multiple countries.
Question
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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