Not if mistaken that Co can't return capital as a dividend. It can. @jeremydcape @MForstater @BarrickGold @AntnRueh @stephen_abbott
#Tax tweeps - can u help some #transparency tweeps understand the @BarrickGold Tanzania case http://www.tra.go.tz/images/uploads/decidedcases/african%20barick.pdf … -whats going on here?https://twitter.com/AntnRueh/status/783317939290251265 …
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bottom page 19 top of page 20 is 100% wrong for a UK Co.
@jeremydcape@MForstater@BarrickGold@AntnRueh@stephen_abbott - 2 more replies
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Thanks so much to all of you for looking into this!
@Semkae@stephen_abbott@hselftax@Open_Oil - End of conversation
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You have to question why no UK co law expert was called.
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I just feel for their advisors!
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looks like dividends were paid out of capital contribution. Difficult to tie the div's to any particular activites.
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They cited Ramsay. To make a UK plc Tanzanian tax resident.
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Tanzania saw ops locally (140 employees) & decided to say U.K. Co was Tz res. Did not understand cap reduction. Claimed tax. Won
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