New Judgement On Deemed Income Assessment

In a recent decision, the Tax Appeal Tribunal (TAT) says the tax authority must act reasonably in the exercise of its discretion to assess a taxpayer based on deemed income (or best of judgment assessment).  In the particular case, the TAT ruled that a deemed income assessment cannot be based on general expectation or what was imposed on another company.

The TAT also ruled that although the taxpayers being assessed are the employees, the employer can challenge the assessment to the extent that it alleges a breach of the employer's statutory role as an agent of the tax authority.

Read our tax alert and a copy of the judgement below.

Download Tax Alert_TAT Decision on Deemed Income Assessment