Question Tag: Profit repatriation

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Suppose the South African government changes its policy on profit repatriation and legislates that profit cannot be repatriated until termination or exit.

i) If Rock can invest blocked funds in South Africa for a 12% annual rate of return, by how much would the project’s NPV differ from your results in sub-question (a) above?
(5 marks)

ii) Suggest THREE (3) ways through which Rock can deal with the risk of blocked funds.
(3 marks)

i) Evaluation of impact of restriction on profit repatriation on the NPV
With a restriction on repatriation until exit, all cash returns from year 3 to the end of year 5 will be available to Rock only at the end of year 5 when it exits. As blocked funds can be invested at 12% in South Africa until the end of year 5, the amount that will be repatriated at the end of year 5 is the aggregate future value of the cash returns from year 3 to year 5.


Change in NPV: The NPV decreases by 3.7% compared to the original NPV of GH¢34.325 million.

ii) Suggestions for dealing with blocked funds
Rock Minerals Ltd can manage the risk of blocked funds by implementing any of the following strategies:

  1. Negotiate with the South African government for a stable profit repatriation policy to avoid restrictions.
  2. Sell goods or services to the subsidiary in South Africa and obtain payment for these services or goods to repatriate funds indirectly.
  3. License the subsidiary to use proprietary production processes protected by patents and receive royalties.
  4. Offer management services to the subsidiary and charge a fee for these services, enabling the transfer of funds.
  5. Increase loan financing rather than equity financing, allowing the subsidiary to repay loans with interest payments instead of relying on profit repatriation.

Trolex Ltd was incorporated in the United Kingdom. It manufactures watches for sale only in the Asian Markets. The company is a success story from its commercial enterprise in its production of “wonder watches.”

Vielo Ltd, a locally incorporated company with 4 shareholders, scanned the environment with the bid to start a business that would make it successful. The management of Vielo Ltd heard of the “wonder watches” sold by Trolex Ltd. Consequently, the management of Vielo Ltd placed an order for 10 million watches from Trolex Ltd. From the analysis, Trolex Ltd would make £600,000 from this transaction as profit. The sales value to be transferred to Trolex Ltd by Vielo Ltd amounts to £900 million.

The management of Vielo Ltd has written to the Kaneshie Office of the Ghana Revenue Authority on the tax implication of the payment.

Required:
Advise the Commissioner-General through the office manager on the tax implication of the profit and the transfer payment.

From the available information, Trolex Ltd is not trading in Ghana but with Ghana. The profit generated from the transaction and the payment transferred are not subject to tax in Ghana. Vielo Ltd approached Trolex Ltd for the purchase of the wonder watches, and there is no indication that Trolex Ltd has any presence in Ghana that would make it liable to taxation in Ghana.

Conclusion:
Both the profit (£600,000) and the amount transferred (£900 million) are not liable to tax in Ghana.
(4 marks)