Question Tag: Tax treaties

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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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  • 10 Marks

AT – Aug 2022 – L3 – Q2a – International taxation

Discuss whether bilateral double taxation conventions are essential for resolving international tax problems.

Despite the growing number of contributions to bilateral double taxation, some tax analysts have questioned whether bilateral double taxation conventions relating to the taxation of income and capital are essential for the resolution of international tax problems.

Required:
Discuss the above statement.
(10 marks)

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  • 20 Marks

AT – May 2020 – L3 – Q1 – International taxation

Explanation of the concept of permanent establishment in Ghana and the differences between economic and juridical double taxation.

The spectrum of investment opportunities in Ghana has heightened and this has attracted some investors who intend to visit next month to assess the potential for investment. The Ministry of Finance has written to your Tax Consulting Firm to make a presentation on behalf of the Ministry to these Investors. The letter from the Ministry contains in part the following:

“International trade has given persons the ability to carry out separate aspects of their business operations in different countries. Even though it will be inconceivable to compel a person to pay taxes in every country where that person carries out business operations, the level of business activity carried on by a person in a particular country may expose that person to tax liabilities under the laws of that country. In Ghana, assessable income of a non-resident person includes income effectively connected with a Ghanaian permanent establishment of the person irrespective of the source of the income…”

Required: Prepare a report highlighting the following:

a) What constitutes a Ghanaian permanent establishment with reference to the Income Tax Act, 2015 (Act 896)?
(4 marks)

b) Explain the taxation rules on Ghanaian permanent establishment as enshrined in the Income Tax Act, 2015 (Act 896).
(10 marks)

c) There are economic double taxation and juridical double taxation. Explain these TWO (2) concepts of double taxation.
(6 marks)

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  • 10 Marks

AT – Nov 2020 – L3 – Q2a – Tax planning

A presentation on five objectives of international taxation treaties.

You are a partner in a Tax Consulting firm. Your firm has recently employed 5 new staff and they have to be trained on a number of issues.

Required:
Prepare a presentation on international taxation with emphasis on FIVE (5) objectives or goals of international taxation treaties.

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  • 8 Marks

AT – Mar 2024 – L3 – Q1b – International taxation

Discussing the challenges posed by double taxation agreements and the methods of granting double taxation relief.

There is growing attention on the question of tax treaties signed by developing countries. The costs of tax treaties to developing countries have been highlighted in recent years by NGOs such as ActionAid and SOMO (Lewis, 2013). During 2014, an influential IMF paper warned that developing countries “would be well-advised to sign treaties only with considerable caution” (IMF, Spillovers on International Corporate Taxation, 2014) and the OECD, as part of its Base Erosion and Profit Shifting (BEPS) project, proposes to add text to the commentary of its model treaty to help countries decide “whether a treaty should be concluded with a State but also whether a State should seek to modify or replace an existing treaty or even, as a last resort, terminate a treaty” (OECD, Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, 2014).

Required:

i) Examine the challenges double taxation agreements pose to Ghana.
(4 marks)

ii) Explain the methods of granting double taxation reliefs.
(4 marks)

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  • 2 Marks

AT – March 2023 – L3 – Q3e – International taxation

Assess the reasons for countries entering into tax treaties and their importance in reducing tax barriers.

Countries have enjoyed tax treaties while others have criticised the whole idea of tax treaty arrangements. Treaties may be bilateral or multilateral. Many countries weigh the benefits of treaties before they enter into them in order not to lose out.

Required:
Assess the rationale for tax treaties. (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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  • 10 Marks

AT – Aug 2022 – L3 – Q2a – International taxation

Discuss whether bilateral double taxation conventions are essential for resolving international tax problems.

Despite the growing number of contributions to bilateral double taxation, some tax analysts have questioned whether bilateral double taxation conventions relating to the taxation of income and capital are essential for the resolution of international tax problems.

Required:
Discuss the above statement.
(10 marks)

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  • 20 Marks

AT – May 2020 – L3 – Q1 – International taxation

Explanation of the concept of permanent establishment in Ghana and the differences between economic and juridical double taxation.

The spectrum of investment opportunities in Ghana has heightened and this has attracted some investors who intend to visit next month to assess the potential for investment. The Ministry of Finance has written to your Tax Consulting Firm to make a presentation on behalf of the Ministry to these Investors. The letter from the Ministry contains in part the following:

“International trade has given persons the ability to carry out separate aspects of their business operations in different countries. Even though it will be inconceivable to compel a person to pay taxes in every country where that person carries out business operations, the level of business activity carried on by a person in a particular country may expose that person to tax liabilities under the laws of that country. In Ghana, assessable income of a non-resident person includes income effectively connected with a Ghanaian permanent establishment of the person irrespective of the source of the income…”

Required: Prepare a report highlighting the following:

a) What constitutes a Ghanaian permanent establishment with reference to the Income Tax Act, 2015 (Act 896)?
(4 marks)

b) Explain the taxation rules on Ghanaian permanent establishment as enshrined in the Income Tax Act, 2015 (Act 896).
(10 marks)

c) There are economic double taxation and juridical double taxation. Explain these TWO (2) concepts of double taxation.
(6 marks)

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  • 10 Marks

AT – Nov 2020 – L3 – Q2a – Tax planning

A presentation on five objectives of international taxation treaties.

You are a partner in a Tax Consulting firm. Your firm has recently employed 5 new staff and they have to be trained on a number of issues.

Required:
Prepare a presentation on international taxation with emphasis on FIVE (5) objectives or goals of international taxation treaties.

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  • 8 Marks

AT – Mar 2024 – L3 – Q1b – International taxation

Discussing the challenges posed by double taxation agreements and the methods of granting double taxation relief.

There is growing attention on the question of tax treaties signed by developing countries. The costs of tax treaties to developing countries have been highlighted in recent years by NGOs such as ActionAid and SOMO (Lewis, 2013). During 2014, an influential IMF paper warned that developing countries “would be well-advised to sign treaties only with considerable caution” (IMF, Spillovers on International Corporate Taxation, 2014) and the OECD, as part of its Base Erosion and Profit Shifting (BEPS) project, proposes to add text to the commentary of its model treaty to help countries decide “whether a treaty should be concluded with a State but also whether a State should seek to modify or replace an existing treaty or even, as a last resort, terminate a treaty” (OECD, Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, 2014).

Required:

i) Examine the challenges double taxation agreements pose to Ghana.
(4 marks)

ii) Explain the methods of granting double taxation reliefs.
(4 marks)

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  • 2 Marks

AT – March 2023 – L3 – Q3e – International taxation

Assess the reasons for countries entering into tax treaties and their importance in reducing tax barriers.

Countries have enjoyed tax treaties while others have criticised the whole idea of tax treaty arrangements. Treaties may be bilateral or multilateral. Many countries weigh the benefits of treaties before they enter into them in order not to lose out.

Required:
Assess the rationale for tax treaties. (2 marks)

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