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Income Declaration Scheme declarations provide personal immunity...
Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verification.
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Income Declaration Scheme declarations provide personal immunity only to declarants, but an accepted, tax-paid declaration may evidence the true source of share-capital and share-premium credits in another taxpayer's books where it specifically covers the credits and remains unrebutted; taxing that same income again risks double taxation. Before the source-of-source proviso applied, the taxpayer's burden for such credits was limited to identity, genuineness and creditworthiness, although apparent routing of its own advances through intermediaries required verification of commercial rationale. A banking trail alone does not exclude prior cash funding, requiring examination of relevant admissions. A search statement directly linking accommodation entries to the taxpayer supplies tangible material for a reason to believe; objections need not be disposed of in a separate speaking order where recorded reasons independently sustain jurisdiction.
Income Declaration Scheme declarations provide personal immunity only to declarants, but an accepted, tax-paid declaration may evidence the true source of share-capital and share-premium credits in another taxpayer's books where it specifically covers the credits and remains unrebutted; taxing that same income again risks double taxation. Before the source-of-source proviso applied, the taxpayer's burden for such credits was limited to identity, genuineness and creditworthiness, although apparent routing of its own advances through intermediaries required verification of commercial rationale. A banking trail alone does not exclude prior cash funding, requiring examination of relevant admissions. A search statement directly linking accommodation entries to the taxpayer supplies tangible material for a reason to believe; objections need not be disposed of in a separate speaking order where recorded reasons independently sustain jurisdiction.
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