- 20 Marks
IT – Feb 2020 – L1 – Q3 – Double Taxation and Relief
Advise Mauritius on double taxation relief for investments in Ghana under proposed DTA.
Question
Mauritius seeks to enter into a Double Taxation Agreement (DTA) with Ghana. From the context of the consultation so far held with Ghana, it is evident that Mauritius intends to negotiate the DTA in order to enable its corporate sector to invest capital in Ghana. Mauritius and Ghana operate worldwide system of taxation, but Ghana has high tax rate than Mauritius.
The Minister of Finance in Mauritius approached Kinsful Tax Practitioners, a Chartered Tax Practitioners, in Ghana to advise Mauritius on the most appropriate method of double taxation relief to be included in the proposed Ghana/Mauritius Double Taxation Agreement as it impacts on portfolio investment, direct share ownership and permanent establishment.
Required
(a). As the Head of Tax at Kinsful Tax Practitioners, prepare a briefing note to the Minister of Finance of Mauritius in which you set out your advice.
(bi). State the process by which a Double Taxation Agreement can be operative in Ghana.
(bii). When interpreting a Double Taxation Agreement (DTA), where a term is not defined in the DTA itself, what should the parties do?
Find Related Questions by Tags, levels, etc.
- Tags: Domestic Law, Double Taxation Agreement, OECD MTC, Treaty Interpretation
- Level: Level 1
- Topic: Tax Treaties and Interpretation
- Series: FEB 2020
