Page 52 - UUBO Deal Academy 2020 - Materials
P. 52
Finance Act 2019 – Changes impacting Group
structure and reorganizations
Dividend tax
Thin capitalization
Exemption from CIT 30% of EBITDA for interest
for retained earnings deductibility on foreign
already subject to related party loans. Any
tax, franked income, excess deduction can be
distribution by REIT carried forward for 5 years
or already taxed A blend of benefits
income under PPTA, and pains from
PITA and CGTA
proposed changes to
Nigeria’s tax
regulatory framework
affecting group
structure
Business restructuring
One year minimum legal existence
Allowable deduction required for tax free business
restructuring by related parties.
Related party expenses Also, assets transferred not to be
subject to transfer pricing sold until 1 year post-restructuring
rules; expense attributable to
exempt income not deductible
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