The Tribunal has studied both parties

The Appellant argued that the assessments were based on the
Respondent's wrong assumption that the amounts advanced by JMN
Investments Limited were a loan, a fact that the Appellant disputes.
The Appellant contended that the amounts were advanced to the
Appellant on instructions of the shares of JMN Investments
Limited on a personal capacity and ,the same "were held on trust to
JMN Investments Limited and are therefore not loans.



8. The Appellant submitted documents in issue were investment
funds injected by the company shareholders to acquire property and
for refurbishment purposes. This was done on the fact that the
company was newly incorporated and didn

Tribunal is satisfied that the Appellant
declared the funds advanced in its end year 2011 financial statements
that the same were to be repaid, which amounts were advanced by a
non-resident person and it was on this basis that the Respondent
correctly assessed and charged withholding tax on deemed interest.
Judgement Appeal No. 14 of 2015 Page 5
23. The upshot of the above is that the Tribunal finds that the Appeal
herein lacks merit and is accordingly dismissed. There will be no orders