Question Tag: Non-resident taxation

Search 500 + past questions and counting.
  • Filter by Professional Bodies

  • Filter by Subject

  • Filter by Series

  • Filter by Topics

  • Filter by Levels

IT – Feb 2020 – L1 – Q1 – Taxation of Non-Residents

Advise on UK tax liability for payments to a Ghanaian company under Ghana-UK DTA.

Dzoboku Lullaby Limited is a Ghanaian music and orchestral company. Syntax Promotion, a company resident in the United Kingdom, extended an invitation to Dzoboku Lullaby Limited to a musical concert held in London in December, 2019.

Professor Abu, an employee of Dzoboku Lullaby Limited, was billed to perform for Syntax at two separate concerts in London, one at Gustaff Hall and the other at Gibson Hall. The following payments were made to Dzoboku Lullaby Limited by Syntax Promotion:
a. £100,000 for the public performance at the Gustaff Hall.
b. £20,000 for using the Professor’s image to advertise. The payment was deposited into Dzoboku Lullaby Limited’s bank account.
c. £50,000 for the cancellation of Gibson Hall’s event.
d. 2% of the gate proceeds received.
e. 20% of income that accrued from businesses that advertised at the Gustaff Hall event.

Her Majesty Revenue and Customs (HMRC) in the United Kingdom wrote to the Syntax Promotion demanding tax in respect of all incomes paid to Dzoboku Lullaby Limited. Syntax objected to the HMRC request stating that Dzobuku Lullaby Limited has no Permanent Establishment in the United Kingdom and, therefore, cannot be liable for a United Kingdom tax on business income earned by Dzoboku Lullaby Limited since there is a double tax agreement between Ghana and the United Kingdom.

Think Tank Consulting, a firm of Chartered Tax Practitioners in Accra was consulted by Syntax Promotion to advise them on the HMRC demand.

You are a Chartered Tax Practitioner in the employment of Think Tank Consulting and Syntax request was referred to you to deal with by your Managing Partner.

Required
Prepare a briefing note to the Managing Partner of Think Tank Consulting in which you set out clearly, with reasons, whether United Kingdom’s tax is due on each of the payments made to Dzoboku Lullaby Company Limited as demanded by the HMRC.

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "IT – Feb 2020 – L1 – Q1 – Taxation of Non-Residents"

PT – Nov 2024 – L2 – Q5a – Notification to Commissioner-General for Non-Resident Contracts

Requirements for notifying the Commissioner-General when a resident contracts a non-resident.

For the purpose of withholding tax, the Income Tax Act, 2016 (Act 896) requires a resident person who enters into a contract with a non-resident person which gives rise to income from Ghana to notify the Commissioner-General within thirty (30) days.

Required:

State the items that must be detailed in the notification to the Commissioner-General.

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "PT – Nov 2024 – L2 – Q5a – Notification to Commissioner-General for Non-Resident Contracts"

PT – Nov 2024 – L2 – Q3a – Tax Treatment of Employee Compensation

Explains the tax treatment of various types of employee compensation under the Income Tax Act, 2015 (Act 896).

Describe the tax treatment of the following transactions in the context of the Income Tax Act, 2015 (Act 896).

i) Payment of GH¢2,500 salary for a casual worker in the month of Feb 2024. 
ii) Payment of Bonus of GH¢32,000 to an employee with an Annual Basic salary of GH¢180,000. 
iii) Payment of GH¢3,200 to a temporary worker in the month of July 2024. 
iv) Payment of income to a non-resident employee in Ghana. 
v) Redundancy payment to an employee.

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "PT – Nov 2024 – L2 – Q3a – Tax Treatment of Employee Compensation"

TF – May 2018 – L3 – Q4a – Permanent establishment

Discuss how a non-resident person is taxed in Ghana with and without a permanent establishment.

Tax administration allows for cross-border transactions. To this end, entities conduct businesses across countries as a way of increasing their competitiveness and international appeal and consequently their profits.

Required:
Discuss how a non-resident person would be taxed in Ghana if they:
i) Have a permanent establishment.
ii) Do not have a permanent establishment.
(4 marks)

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "TF – May 2018 – L3 – Q4a – Permanent establishment"

AT – March 2023 – L3 – Q3c – International taxation

Discuss the extent to which foreign companies are liable to tax in Ghana.

“Foreign companies which are non-resident can ply their businesses in Ghana and will not pay taxes in Ghana but rather in their home countries.” This was a statement that was made at a tax forum in Ghana as part of tax planning measures by a young tax graduate, who was asked to share his thoughts on non-resident persons and their tax issues. This created some arguments at the programme.

Required:
To what extent should foreign companies be liable to tax in Ghana?

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "AT – March 2023 – L3 – Q3c – International taxation"

IT – Feb 2020 – L1 – Q1 – Taxation of Non-Residents

Advise on UK tax liability for payments to a Ghanaian company under Ghana-UK DTA.

Dzoboku Lullaby Limited is a Ghanaian music and orchestral company. Syntax Promotion, a company resident in the United Kingdom, extended an invitation to Dzoboku Lullaby Limited to a musical concert held in London in December, 2019.

Professor Abu, an employee of Dzoboku Lullaby Limited, was billed to perform for Syntax at two separate concerts in London, one at Gustaff Hall and the other at Gibson Hall. The following payments were made to Dzoboku Lullaby Limited by Syntax Promotion:
a. £100,000 for the public performance at the Gustaff Hall.
b. £20,000 for using the Professor’s image to advertise. The payment was deposited into Dzoboku Lullaby Limited’s bank account.
c. £50,000 for the cancellation of Gibson Hall’s event.
d. 2% of the gate proceeds received.
e. 20% of income that accrued from businesses that advertised at the Gustaff Hall event.

Her Majesty Revenue and Customs (HMRC) in the United Kingdom wrote to the Syntax Promotion demanding tax in respect of all incomes paid to Dzoboku Lullaby Limited. Syntax objected to the HMRC request stating that Dzobuku Lullaby Limited has no Permanent Establishment in the United Kingdom and, therefore, cannot be liable for a United Kingdom tax on business income earned by Dzoboku Lullaby Limited since there is a double tax agreement between Ghana and the United Kingdom.

Think Tank Consulting, a firm of Chartered Tax Practitioners in Accra was consulted by Syntax Promotion to advise them on the HMRC demand.

You are a Chartered Tax Practitioner in the employment of Think Tank Consulting and Syntax request was referred to you to deal with by your Managing Partner.

Required
Prepare a briefing note to the Managing Partner of Think Tank Consulting in which you set out clearly, with reasons, whether United Kingdom’s tax is due on each of the payments made to Dzoboku Lullaby Company Limited as demanded by the HMRC.

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "IT – Feb 2020 – L1 – Q1 – Taxation of Non-Residents"

PT – Nov 2024 – L2 – Q5a – Notification to Commissioner-General for Non-Resident Contracts

Requirements for notifying the Commissioner-General when a resident contracts a non-resident.

For the purpose of withholding tax, the Income Tax Act, 2016 (Act 896) requires a resident person who enters into a contract with a non-resident person which gives rise to income from Ghana to notify the Commissioner-General within thirty (30) days.

Required:

State the items that must be detailed in the notification to the Commissioner-General.

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "PT – Nov 2024 – L2 – Q5a – Notification to Commissioner-General for Non-Resident Contracts"

PT – Nov 2024 – L2 – Q3a – Tax Treatment of Employee Compensation

Explains the tax treatment of various types of employee compensation under the Income Tax Act, 2015 (Act 896).

Describe the tax treatment of the following transactions in the context of the Income Tax Act, 2015 (Act 896).

i) Payment of GH¢2,500 salary for a casual worker in the month of Feb 2024. 
ii) Payment of Bonus of GH¢32,000 to an employee with an Annual Basic salary of GH¢180,000. 
iii) Payment of GH¢3,200 to a temporary worker in the month of July 2024. 
iv) Payment of income to a non-resident employee in Ghana. 
v) Redundancy payment to an employee.

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "PT – Nov 2024 – L2 – Q3a – Tax Treatment of Employee Compensation"

TF – May 2018 – L3 – Q4a – Permanent establishment

Discuss how a non-resident person is taxed in Ghana with and without a permanent establishment.

Tax administration allows for cross-border transactions. To this end, entities conduct businesses across countries as a way of increasing their competitiveness and international appeal and consequently their profits.

Required:
Discuss how a non-resident person would be taxed in Ghana if they:
i) Have a permanent establishment.
ii) Do not have a permanent establishment.
(4 marks)

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "TF – May 2018 – L3 – Q4a – Permanent establishment"

AT – March 2023 – L3 – Q3c – International taxation

Discuss the extent to which foreign companies are liable to tax in Ghana.

“Foreign companies which are non-resident can ply their businesses in Ghana and will not pay taxes in Ghana but rather in their home countries.” This was a statement that was made at a tax forum in Ghana as part of tax planning measures by a young tax graduate, who was asked to share his thoughts on non-resident persons and their tax issues. This created some arguments at the programme.

Required:
To what extent should foreign companies be liable to tax in Ghana?

Login or create a free account to see answers

Find Related Questions by Tags, levels, etc.

Report an error

You're reporting an error for "AT – March 2023 – L3 – Q3c – International taxation"

Oops!

This feature is only available in selected plans.

Click on the login button below to login if you’re already subscribed to a plan or click on the upgrade button below to upgrade your current plan.

If you’re not subscribed to a plan, click on the button below to choose a plan