ARTICLE
7 January 2015

What Constitutes Turnover For A Nonresident Company, And When Does Tax Default Interest Start To Count?

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PwC Nigeria

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PwC Nigeria is one of the leading professional services ?rms in Nigeria with of?ces in Lagos, Abuja and Port Harcourt, with over 1,000 staff and 31 resident partners. We are committed to serving as a force for integrity, good sense and wise solutions to the problems facing businesses and the capital markets. We are guided by one promise – to do what is right, be it with our people, clients, community, or environment.
The Tax Appeal Tribunal ("TAT") on 11 December 2014 delivered a judgment on the treatment of revenue allocation by a non-resident company ("NRC") under the deemed profit regime.
Nigeria Tax

The Tax Appeal Tribunal ("TAT") on 11 December 2014 delivered a judgment on the treatment of revenue allocation by a non-resident company ("NRC") under the deemed profit regime. The TAT relied on the recent judgment of the Court of Appeal ("CA") in the Halliburton case, and ruled that where an NRC is assessed to tax on deemed profits basis, further deductions (outside the deemed cost) cannot be taken in any form.

On interest and penalties, the TAT took the position that interest on additional assessment will only start to accrue 2 months after an undisputed assessment has been served and not when the disputed assessment was raised or when the self-assessment returns were filed.

Download PwC Tax Alert_Revenue Determination & Default Interest

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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