Trinidad & Tobago_ Deductibility on the management charge
The judgement for the pricing agreement was recently released. The case was determined in favor of the taxpayer (see page 213), however the decision was not based on law, but rather on a balance of probabilities and from testimony from witnesses, due to the lack of documentation from the period in question. As such, if the company wishes to claim the expenses for the prior years, we have also summarized the sums treated as non-deductible amount G. DISPOSITION 83. For reasons as have been enunciated hereinabove, it is therefore our decision that: - a. the assessment made by the Respondent on the Appellant for the year of income 2005 with respect to Corporation Tax and in which the Respondent assessed the Appellant to additional sales revenue of $439, 183,501 and to have also reduced the Appellant’s losses carried forward from $73,754,282 to nil to be unjustified as a matter of fact and law; and b. the total adjustments to sales made by the Respondent on the Appellant for the ...