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.
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