UNITED CAPITAL ASSETS MANAGEMENT LTD V. FIRS (TAX APPEAL JUDGMENT)

ISSUES FOR DETERMINATION

The Respondent formulated the following issues for determination to wit:

i. Whether the provision of Section 19 of the Companies Income Tax Act was properly applied to the subject matter of this appeal:

ii. Whether the Appellant was entitled to relief sought under Executive Order No.004 of 2017 on the Voluntary Assets and Income Declaration Scheme; and

iii. Whether the Appeal lacking in merit ought to be dismissed and the demand of the Respondent ought to be upheld as claimed from the Appellant.

On the other hand, the Appellant formulated two issues for determination as follows:

i. Whether having regard to the provision of the Companies Income Tax (Exemption of Bonds and Short-Term Government Securities) Order 2011, the Respondent was right to subject the Appellant to tax on exempt income: and

ii. Whether the Appellant is entitled to relief sought under Executive Order No.004 of 2017 on the Voluntary Assets and Income Declaration Scheme.