Anti-avoidance Rules

STP – Feb 2007 – L3 – Q2 – Employee Taxation

Outline Ghanaian tax and social security implications for a French employee working in Ghana under a Double Tax Treaty.

Question

Mr. Nor Amid, the Human Capital Resource Person of Amanda Inc, an entity registered in France sends a brief note to you in respect of a duty tour of an employee as follows:
“Amanda is sending an employee to Ghana and I am hoping that you could provide guidance for Amanda. Our understanding is as that:

The employee is French and may be kept on the French payroll
The employee’s remuneration will be cross charged to Amanda in France and Ghana
The employee, according to French Tax Law, will be French for tax purposes
The employee will spend 40% or less of his time in France
The employee will spend between 40 to 60% of his time in Ghana and whilst in Ghana the employee will be accommodated in hotels, will have free use of car with fuel and free meal.
The employee will spend his time in Ghana from 7 to 25 days at a time depending on need.

Would you kindly provide us with a brief outline of the Ghanaian tax and social security implications for Amanda and the employee? Kindly note that Ghana has an operating ‘Double Tax Treaty’ with France.

Required:
(a). Please submit a memo to respond to the concerns raised by Mr. Nor Amid.

(b). Ghana has general tax-avoidance rules in the tax acts. Kindly discuss any three practice methods adopted by the Revenue Agencies to regulate transfer pricing between related parties?

Answer

Find Related Questions by Tags, levels, etc.

Tags: Anti-Avoidance, Customs Valuation, Related parties, Tax adjustments, Transfer Pricing
Level: Level 3

Topic: Anti-avoidance Rules
Series: FEB 2007

STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation

Discuss tax implications of financing a company with debt or equity and recommend the preferable option.

Question

(a). The Chief Executive Officer (CEO) of Expedia intends expanding his business operations in Ghana. The CEO is particularly interested in the income tax consequences of financing the activities of businesses in Ghana. As a tax consultant of high repute, the CEO seeks your opinion on the income tax implications of equity financing and debt financing.

Required:

Write an opinion on the tax implications of financing the activities of a company with either debt or equity and state the preferable option of financing.

(b). Some entrepreneurs hold the view that it is better to finance the activities of a business with related-party loans than with loans provided by unrelated parties. This view is based on the idea that all interest paid on loans are deductible for tax purposes in the books of the borrower and the entrepreneur can manipulate the interest rate which will ultimately affect the corporate taxes the business will pay.

Required: Based on your knowledge of the tax treatment of loans provided by related parties, discuss the truthfulness or otherwise of the above assertion.

Answer

Find Related Questions by Tags, levels, etc.

Tags: Arm's Length Transactions, Related-Party Loans, Tax avoidance, Thin Capitalization
Level: Level 2

Topic: Anti-avoidance Rules
Series: AUG 2018

STP – Feb 2007 – L3 – Q2 – Employee Taxation

Outline Ghanaian tax and social security implications for a French employee working in Ghana under a Double Tax Treaty.

Question

The employee is French and may be kept on the French payroll
The employee’s remuneration will be cross charged to Amanda in France and Ghana
The employee, according to French Tax Law, will be French for tax purposes
The employee will spend 40% or less of his time in France
The employee will spend between 40 to 60% of his time in Ghana and whilst in Ghana the employee will be accommodated in hotels, will have free use of car with fuel and free meal.
The employee will spend his time in Ghana from 7 to 25 days at a time depending on need.

Required:
(a). Please submit a memo to respond to the concerns raised by Mr. Nor Amid.

(b). Ghana has general tax-avoidance rules in the tax acts. Kindly discuss any three practice methods adopted by the Revenue Agencies to regulate transfer pricing between related parties?

Answer

Find Related Questions by Tags, levels, etc.

Tags: Anti-Avoidance, Customs Valuation, Related parties, Tax adjustments, Transfer Pricing
Level: Level 3

Topic: Anti-avoidance Rules
Series: FEB 2007

STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation

Discuss tax implications of financing a company with debt or equity and recommend the preferable option.

Question

Required:

Write an opinion on the tax implications of financing the activities of a company with either debt or equity and state the preferable option of financing.

Required: Based on your knowledge of the tax treatment of loans provided by related parties, discuss the truthfulness or otherwise of the above assertion.

Answer

Find Related Questions by Tags, levels, etc.

Tags: Arm's Length Transactions, Related-Party Loans, Tax avoidance, Thin Capitalization
Level: Level 2

Topic: Anti-avoidance Rules
Series: AUG 2018

Topic: Anti-avoidance Rules

Filter by Professional Bodies

Filter by Subject

Filter by Series

Filter by Topics

Filter by Levels

STP – Feb 2007 – L3 – Q2 – Employee Taxation

Outline Ghanaian tax and social security implications for a French employee working in Ghana under a Double Tax Treaty.

STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation

Discuss tax implications of financing a company with debt or equity and recommend the preferable option.

STP – Feb 2007 – L3 – Q2 – Employee Taxation

Outline Ghanaian tax and social security implications for a French employee working in Ghana under a Double Tax Treaty.

STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation

Discuss tax implications of financing a company with debt or equity and recommend the preferable option.

Our offerings

Community

Contact Info

Customer

Get In Touch

Topic: Anti-avoidance Rules

Filter by Professional Bodies

Filter by Subject

Filter by Series

Filter by Topics

Filter by Levels

STP – Feb 2007 – L3 – Q2 – Employee Taxation

Outline Ghanaian tax and social security implications for a French employee working in Ghana under a Double Tax Treaty.

You're reporting an error for "STP – Feb 2007 – L3 – Q2 – Employee Taxation"

STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation

Discuss tax implications of financing a company with debt or equity and recommend the preferable option.

You're reporting an error for "STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation"

STP – Feb 2007 – L3 – Q2 – Employee Taxation

Outline Ghanaian tax and social security implications for a French employee working in Ghana under a Double Tax Treaty.

You're reporting an error for "STP – Feb 2007 – L3 – Q2 – Employee Taxation"

STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation

Discuss tax implications of financing a company with debt or equity and recommend the preferable option.

You're reporting an error for "STP – Aug 2018 – L2 – Q2 – Tax Strategies for New Business Formation"

Our offerings

Community

Contact Info

Customer

Get In Touch

admin

Pick a Form