Misclassification- Withholding Tax on accommodation and transport costs paid for contractors as management and professional fees.

Key Issue: Whether the Respondent erred in imposing Withholding Tax on accommodation and transport costs paid to contractors, treating them as management or professional fees.

The Tribunal found that the Respondent misapplied the tax provisions by charging Withholding Tax on payments to transport providers and hotel accommodation. The payments were incorrectly categorized as management fees, professional fees, or even interest, resulting in an unwarranted 20% tax rate.