INTERNATIONAL TAXATION

International taxation arises between individual(s) or corporate(s) bodies operating within two or more countries.

Issue arising are stated below.
1.Individual's income being subject to tax in two or more countries.
2.Company's income being subject to tax in two or more countries.
3.Individual being subject to tax in two or more countries.
4.Transaction(s) in a country being subject to tax in two or more countries.  

DOUBLE TAXATION RELIEF

Double taxation relief is an arrangement which recognize tax paid in other countries and allows a relief for it.

-Their are double taxation arrangements(in Nigeria) with some countries listed below.
  UK, Canada, China, South Africa, France, Belgium, Netherland and others.

COMMON WEALTH DOUBLE TAXATION RELIEF

 Nigerian company which is liable to pay tax under the Company  Income Tax Act(CITA) in Nigeria for any  year on any part of its profits proves to the satisfaction of the board that is has suffered or, deems to suffer Commonwealth income tax for that tax year in respect of that part of its profit, it shall be entitled to relief from tax paid or payable by it under CITA on the part of profit at a rate thereon to be determined as follows.

(I) If the Common Wealth(CW) rates does not exceed one-half of the rate of tax under this Act,
 the rate at which relief is to be given shall be the CW rate.

(II) In any other case, the rate at which relief is to be given shall be half  of the rate of tax  under this Act.

If  any Foreign company is liable to pay tax under the CITA for any tax year on any part of its profit
is subject to tax by the Service and suffered  or deemed  to suffer CW income tax for that year in respect of its profit, it shall be entitled to relief at a rate thereon to be determined as follows-

(i)If the CW rate of tax does not exceeds  the rate under this Act, the rate at which reliefs is to be given shall be 1/2 of the CW rate.

(ii) If the CW rate exceeds the rate of tax under this Act, the rate at which reliefs is to be given shall
be given shall be equal to the amount by which the rate of tax under this Act exceeds one-half of the 
CW rate.


NOTE.

Nigeria Tax Rate = Tax Paid/Tax Payable in Nigeria/Income .


Commonwealth Rate= Tax Paid/Tax Payable in CWC/income.


Reference .
CITA.






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