Suchergebnisse

Abstract
It is an accepted principle that countries have the right to tax residents and nonresidents on their income from business on source or residence. The determination of the residence of a company for tax purposes based on the "management and control" and 'place of effective management' may pose challenges in establishing tax liability of a dual resident corporation. Such challenges cause problems on corporate taxes and transfer pricing between related parties. Similarly, multinational companies may face challenges in ascertaining their tax liability. The new criteria for determination of residence of a company based on mutual agreement under the OECD and UN Models of 2017, have ramification over the two tests. This article analyses residence of a company on the basis of the two tests in Tanzania. It argues that the two tests as used in Tanzania are superseded by new criteria. Finally, it offers a modest proposal for determination of dual resident of a company in Tanzania.