a) Tax implications of Jones Addotey and Maame Abrefa sharing their working time between Ghana and Britain:

1. Residency status:
   • If they spend less than 183 days in Ghana in a 12-month period, they may be considered non-resident for tax purposes in Ghana.
   • This could affect their tax obligations and rates in both countries.
2. Double taxation:
   • Income earned in both countries may be subject to tax in both jurisdictions.
   • They should review the double taxation agreement between Ghana and the UK to determine how to avoid or minimize double taxation.
3. Tax credits:
   • They may be eligible for foreign tax credits in one country for taxes paid in the other, depending on the specific tax laws and agreements between Ghana and the UK.
4. Reporting requirements:
   • They may need to file tax returns in both countries, declaring their worldwide income.
   • This could increase their compliance burden and costs.
5. Social security contributions:
   • They may be required to make social security contributions in both countries, depending on the duration of their stay and specific agreements between Ghana and the UK.
6. Tax rates:
   • The applicable tax rates may differ between Ghana and the UK, potentially affecting their overall tax liability.
7. Currency fluctuations:
   • Income earned in different currencies may be subject to exchange rate fluctuations, which could impact their tax liability.
8. Permanent establishment:
   • If they conduct business activities in both countries, there’s a risk of creating a permanent establishment, which could have significant tax implications for their company.

b) Tax implications for Addofa Ltd if it goes into export or sells in the local market:

1. Local market sales:
   • Subject to standard corporate income tax rates in Ghana.
   • May be liable for VAT on local sales.
2. Export sales:
   • Potential for tax incentives or exemptions on export income.
   • Possible reduced corporate tax rates for export-oriented businesses.
   • VAT zero-rating on exports, allowing for input VAT recovery.
3. Free Zone benefits:
   • If Addofa Ltd qualifies for Free Zone status, it may enjoy tax holidays and other incentives for export-oriented businesses.
4. Transfer pricing considerations:
   • Need to ensure arm’s length pricing for transactions between related entities in different countries.

c) Tax planning opportunities available to the new company to be set up:

1. Location incentives:
   • Explore tax incentives available for businesses located in specific regions or zones in Ghana.
2. Industry-specific incentives:
   • Investigate tax benefits for agro-processing or value-added agricultural products.
3. Export-oriented incentives:
   • Consider structuring the new company to maximize export-related tax benefits.
4. Research and Development (R&D) incentives:
   • Explore tax deductions or credits for R&D activities in poultry processing.

d) Tax compliance obligations for Addofa Ltd at the time of commencement of operations in Ghana:

1. Company registration:
   • Register with the Ghana Revenue Authority (GRA) for tax purposes.
2. Tax Identification Number (TIN):
   • Obtain a TIN for the company and its directors.
3. VAT registration:
   • Register for VAT if turnover exceeds the registration threshold.
4. PAYE registration:
   • Register for Pay As You Earn (PAYE) for employee tax deductions.
5. Filing tax returns:
   • File corporate income tax returns annually.
   • Submit monthly or quarterly VAT returns if registered for VAT.
6. Record keeping:
   • Maintain proper books of accounts and financial records for at least six years.
7. Tax payments:
   • Make provisional tax payments quarterly based on estimated annual income.
   • Pay final corporate tax by the due date after filing the annual return.
8. Withholding taxes:
   • Withhold taxes on certain payments (e.g., dividends, interest) and remit to GRA.