- 15 Marks
AT – Nov 2022 – LEVEL 1 – Q6 – International Taxation
Assess if Singapore residency exempts a company from Nigerian tax, list benefits under Nigeria-Singapore DTA, and state five circumstances for tax liability in Nigeria.
Question
Singapura PTC Limited, a company registered in Singapore, derived a range of income from Nigeria in year 2021 and the tax office in Nigeria had raised an assessment on the company, based on the provisions of Companies Income Tax Act. The company wanted you to object to the assessment, claiming that being a resident of Singapore, it is not liable to tax in Nigeria, as a benefit of the double taxation agreement between Nigeria and Singapore.
Required:
a. Do you agree with the company, that its residence in Singapore qualifies it for tax exemption in Nigeria?
b. What are the benefits that may be available to a resident of Singapore under the double taxation agreement between Nigeria and Singapore?
c. State FIVE circumstances under which a company registered in Singapore will be liable to tax in Nigeria.
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