problem1. List all eight main objectives of tax treaties.
problem2. In respect of an income year, when is an individual treated as resident of Mauritius for income tax purposes?
problem3. Describe the significance of the term “resident” for the application of a Double Tax treaty?
problem4. Make a distinction between “juridical” double taxation and “economic” double taxation.
problem5. Describe carefully how cases of dual residence for both individuals and companies would be resolved by the application of the relevant provisions of tax treaty based on OECD model.
problem6. Bank plc is incorporated and managed in Country A. It wishes to make loans to persons in Country B. Bank plc sets up a representative office in Country B. It rents office space and sends four of its employees to work there. Bank plc also appoints two local clerical staff. The employees collect information on privatisation and economic developments in Country B. Any potential clients who enquire at representative office about getting loans from Bank plc are referred to head office which processes all loan applications, comprising documentation. In the course of making decisions about loan applications, head office often asks the representative office to make various enquiries and provide information about potential borrowers. Does Bank plc have a permanent establishment in Country B? If so, what profits are taxable there? Provide reasons for your answer.