Deemed Interest

“The Tribunal has throughout its life held the position that tax liability cannot be created or extinguished by a technicality. In the instant case, there is no doubt that deemed interest accrued. There is no doubt that deemed interest is subject to WHT. The Tribunal finds that deemed interest on loans from Cheki Africa Limited, a related company domiciled in Mauritius to Brighter Monday.Com were subject to WHT and therefore liable to be collected”