"Ordinarily resident" implies a more permanent status than simply being resident.

Domicile is determined by:

A resident in Jamaica is taxed only on Jamaican income.

Temporary absence abroad does not affect liability if the person remains ordinarily resident in Jamaica.

Non-residents are taxed in Jamaica on:

The Jamaican tax rate for non-resident individuals is:

Persons not domiciled in Jamaica are taxed on:

Section 27 governs taxation of persons not domiciled.

A consultant working in Jamaica for three months is taxed on income whether received in Jamaica or abroad.

Commonwealth citizens not ordinarily resident in Jamaica are taxed only on Jamaican income.

Jamaica has DTAs with all the following EXCEPT:

DTAs prevent taxpayers from being taxed twice on the same income.

CARICOM’s DTA was signed in 1994 by all CSME countries except Suriname.

CARICOM’s DTA ensures income is taxed only in the country where it arises.

Withholding tax applies to entertainers and athletes earning in Jamaica.

Section 40(1) requires agents to withhold tax on rent, royalties, and management fees paid to non-residents.

Business profits are taxable in the country where:

A permanent establishment includes offices, factories, and workshops.

A building site existing for more than six months is considered a permanent establishment.

Profits attributable to a permanent establishment in Jamaica are taxed at normal corporate rates.

Business profits are taxed at 25% for unregulated companies in Jamaica.

Business profits are taxed at 33⅓% for regulated companies in Jamaica.

A branch is considered a permanent establishment under DTAs.

Members of consular services are exempt from Jamaican tax on official salaries.

Venture capital company dividends may be exempt from Jamaican tax for non-residents.

Section 19 addresses transfers of assets abroad to avoid Jamaican tax.

Consultants under technical assistance agreements are exempt from tax on overseas income.

Income derived in Jamaica by technical assistance consultants is taxable.

In Robinson v Agassi, the Privy Council ruled endorsement income connected to UK tournaments was taxable.

Usain Bolt refused to compete in the UK after the Agassi ruling.

The Privy Council ruled that transfers within a single organisation (branch to head office) do not trigger withholding tax.

The Bank of Nova Scotia case confirmed that reimbursements to head office were not subject to withholding tax.

In the Agassi case, Nike and Head had a tax presence in the UK.

Arlene Baker, domiciled in Jamaica but earning UK dividends, is taxed in Jamaica on worldwide income.

James, a Jamaican engineer working temporarily in the Bahamas, remains taxable in Jamaica on worldwide income.

George, a Canadian pensioner staying five months in Jamaica, is taxed on his Canadian pension.

A Brazilian consultant working in Jamaica for three months is taxed on income whether received in Jamaica or abroad.

Non-residents earning interest in Jamaica are subject to withholding tax.

Under the Jamaica–Canada treaty, dividends on portfolio investment are taxed at:

Under the Jamaica–UK treaty, substantial holding dividends are taxed at 22.5%.

Under the Jamaica–China treaty, interest is taxed at 7.5%.

Under the Jamaica–CARICOM treaty, dividends are taxed at 0%.

A person is considered resident in Jamaica if they live in the island for 183 days or more in a year.

"Ordinarily resident" implies a more permanent status than simply being resident. (T/F)

Domicile is determined solely by where a person currently lives, regardless of intent to return. (T/F)

A person may acquire a domicile of choice by residing, working, and establishing family life in another country. (T/F)

Most Jamaican taxpayers are resident, ordinarily resident, and domiciled in Jamaica.

A person’s domicile of origin is derived from their father, or mother if illegitimate. (T/F)

A resident in Jamaica is taxed only on income earned within Jamaica. (T/F)

A resident is liable to Jamaican tax on worldwide income.

Temporary absence abroad does not affect liability if the person remains ordinarily resident in Jamaica.

Section 28 of the Income Tax Act addresses temporary absence.

Non-residents are taxed only on income arising in Jamaica.

The Jamaican tax rate for non-resident individuals is 25%.

The Jamaican tax rate for non-resident companies is 33⅓%.

Non-residents are taxed on worldwide income.

Agents in Jamaica must withhold tax on payments to non-residents.

A non-resident individual is subject to thresholds before tax applies.

Section 29 exempts persons resident for less than six months from tax on overseas income.

George, a Canadian pensioner staying five months in Jamaica, is taxed on his Canadian pension.

Non-residents earning rent from Jamaican property are subject to Jamaican tax.

Non-residents are taxed on annuities and royalties arising in Jamaica.

Persons not domiciled in Jamaica are taxed on Jamaican income and overseas income remitted to Jamaica.

Section 27 governs taxation of persons not domiciled.

A consultant working in Jamaica for three months is taxed on income whether received in Jamaica or abroad.

Persons not domiciled are exempt from tax on Jamaican income.

Commonwealth citizens not ordinarily resident in Jamaica are taxed only on Jamaican income.

Jamaica has DTAs with Canada, UK, USA, and CARICOM countries.

DTAs prevent taxpayers from being taxed twice on the same income.

Under DTAs, Jamaica issues certificates of taxes withheld for credit in the taxpayer’s home country.

CARICOM’s DTA ensures income is taxed only in the country where it arises.

CARICOM’s DTA was signed in 1994 by all CSME countries except Suriname.

CARICOM’s DTA exempts dividends, interest, and royalties from double taxation.

Withholding tax applies to entertainers and athletes earning in Jamaica.

Section 40(1) requires agents to withhold tax on rent, royalties, and management fees paid to non-residents.

The Privy Council ruled in Agassi’s case that endorsement income connected to UK tournaments was taxable.

Usain Bolt refused to compete in the UK after the Agassi ruling.

Business profits are taxable in the country where effective management is exercised.

A permanent establishment includes offices, factories, and workshops.

A warehouse used for storage by others qualifies as a permanent establishment.

A building site existing for more than six months is considered a permanent establishment.

Profits attributable to a permanent establishment in Jamaica are taxed at normal corporate rates.

Jamaica’s DTA with the UK exempts UK enterprises from Jamaican tax unless they have a permanent establishment.

A branch is considered a permanent establishment under DTAs.

Business profits are taxed at 25% for unregulated companies in Jamaica.

Business profits are taxed at 33⅓% for regulated companies in Jamaica.

Article 5(1) of Jamaica’s DTA with the UK defines permanent establishment.

Members of consular services are exempt from Jamaican tax on official salaries.

Venture capital company dividends may be exempt from Jamaican tax for non-residents.

Section 19 addresses transfers of assets abroad to avoid Jamaican tax.

Consultants under technical assistance agreements are exempt from tax on overseas income.

Income derived in Jamaica by technical assistance consultants is taxable.

Expenses must be wholly and exclusively incurred in acquiring the income to be deductible.

In Strong & Co. v Woodifield (1906), damages paid to a hotel guest were allowed as deductible expenses.

Jamaica’s Income Tax Act uses the narrow test “wholly and exclusively incurred in acquiring the income.”

The UK Committee recommended the broader test “for the purposes of the trade.”

Expenses connected with wrongful dismissal of an employee are generally deductible.

Which of the following is NOT listed as allowable under Section 13?

Donations to approved educational institutions or charities are deductible up to: