The Tax Appeal Tribunal (TAT) on 30 July delivered a judgment on the deductibility of recharges by nonresident companies filing income tax returns under the deemed profit regime. This was in respect of a case brought before it by Global Marine Baltic Incorporation (GMBI) against the Federal Inland Revenue Service (FIRS).
The TAT ruled in favour of the FIRS that where a nonresident company is assessed to tax on deemed profit, further deductions (outside the deemed cost) cannot be taken for subcontractor charges.
Below is a copy of our tax alert on the subject.
Download Tax Alert_TAT judgement on the deductibility of recharges by nonresidents_August 2013