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1TAXATION OF NON-RESIDENTS ANDTHEIR AGENTSHARISON SAMARATUNGACTA, ATII, MAAT, B. Sc. (B. Ad) Sp, HNDC

Chartered Tax Advisor andAuthorized RepresentativeHWHS

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CONTENTSIntroduction Imposition of TaxDetermining ResidencyLocation of IncomeSource RulesLiability of Non-ResidentsModification to Source RulesService IncomeBusiness IncomeInterest & Royalty IncomeRent, Ground Rent etc..

2HWHSTax Payable by CompaniesMeaning of RemittancesHead Office ExpensesInstrumentality RuleInstrumentality ProvisionLiability of Local AgentsType of TransactionsProfit as a Percentage of T/OClosely Connected PersonsReliefs for Double TaxationTax Rates

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3HWHSResidence is a material factor for a person in determining tax liability and for the purpose of applying many provisions of any tax legislation. A person resident in the state is liable to tax on his worldwide profits and income while a non-resident is liable to tax on only income which arose or derived from that particular state.Different jurisdictions have different ways of defining tax residence, which creates further complexity for business entities like companies, operating in more than one jurisdiction.Specially non-residents need to ensure that their business entity is only subject to tax in the jurisdiction it is intends to be taxed. Failure to get this right could result in multiple tax liabilities in multiple jurisdictions.INTRODUCTION

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4HWHSThe basic function of a charging section is to impose tax legislated by the parliament. Charging section is in a nutshell, lay down a broad outline within which the whole tax system is operated. The whole system follows after the charging section and it is really an elaboration or an amplification of what is stated in the charging section. Therefore more precisely, the imposition of tax should be clear and unambiguous terms. IMPOSITION OF TAXIn the case called Cape Brandy Syndicate v Inland Revenue Commissioners (1921) 12 TC 358, Judge Sidney Rowlatt expressed his views as; It is urged that in a taxing act, clear words are necessary in order to tax the subject It simply means that in a taxing act, one has to look merely at what is clearly said. There is no room for any intendment There is no presumptions as to a tax. Nothing is to be read in, nothing to be implied, one can look fairly at the language used.

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5HWHSAccordingly, in terms of Section 2 of Inland Revenue Act No. 10 of 2006 (Hereafter referred to as The Act), Income tax shall be charged on the profits and income of every person for any year of assessment;

Wherever arising, in the case of a person who is resident in Sri Lanka in that year of assessment; and

Arising in or derived from Sri Lanka, in the case of every other person. IMPOSITION OF TAX conProfits and income arising in or derived from Sri Lanka includes all profits and income derived from services rendered in Sri Lanka or from property in Sri Lanka, or from business transacted in Sri Lanka, whether directly or through an agent. Person includes a company or body of persons or any government.

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6HWHSThe charging section of The Act has introduced the concept of resident and non-resident which are very important for determining tax liability. This is called as the status of the person which is defined in a Section 79 as;Where a company or a body of persons has,Its registered or principal office in Sri Lanka, orWhere the control and management of its business are exercised in Sri Lanka,such company or body of persons shall be deemed to be resident in Sri Lanka for the purposes of The Act.DETERMINING RESIDENCY Accordingly, if any person does not fulfill both criteria above, such person deemed to be a non-resident for the purpose of taxation in Sri Lanka.

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7HWHSDETERMINING RESIDENCY conIs Registered or Principal Office in Sri Lanka?ResidentYESNOIs Control & Management Exercise in Sri Lanka?YESNOResidentNon-Resident

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8HWHSThis definition has based on some old English cases. Originally the idea was that a company was resident in the country where it was incorporated. But the House of Lords came to a different conclusion in the case of De Beers Consolidated Mines Ltd v Howe (1906) 5 TC 213. It was held that De Beers Consolidated a diamond mining company incorporated in South Africa was liable tax in United Kingdom on the basis of the Board of Directors held their board meeting in UK and made some important policy decision relating to the running of the company.The House of Lords said that the company was resident in UK and Lord Loreburn said;A company resides where its real business is carried on and the real business is carried on where the central management and control actually abides.DETERMINING RESIDENCY con

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9HWHSThis precedent was followed by the number of cases later called;New Zealand Shipping Company v Stephen (1907) 5 TC 553Egyptian Delta Land & Investment Co. Ltd. v Todd (1928) 6 TC 152Bullock v Unit Construction Co. Ltd. (1959) 38 TC 712In Bullock v Unit Construction, African subsidiary company which was incorporated and trading in Africa were held to be resident in the UK by reason of the degree of management and control over their businesses exercised in the UK by the parent company.The decisions in both De Beers and Unit Construction cases make it clear that the place of central management and control is primarily a question of fact. Because the control is exercised by the Board of Directors in accordance with the articles of the company. DETERMINING RESIDENCY con

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10HWHSBasically the question is, where does this income arisen? is important for a non-resident person because, the rule in the case of a non-resident person, only profits and income arising in or derived from Sri Lanka is liable to tax. But occasionally where the income arises may be important even for resident person as a result of existing of some provisions in the act to grant reliefs in respect certain income arose outside Sri Lanka.

Example is certain profits and income derived outside for a person in Sri Lanka is exempted from tax under Section 15 LOCATION OF INCOMETherefore the location of income is significant not only for a non-resident but also for resident person in Sri Lanka, in view of granting reliefs and exemptions or some kind of special treatments such as applying reduced tax rates.

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11HWHSThere are certain rules which are recognized as Source Rules to answer the question where does this income arisen? In plain terms source rules can be described as;

From where income is sourced? orFrom where income is routed? Originally these source rules were the creations of the judges who have decided from where the particular income arose. Therefore these rules came to know as Common Law Rules which can be described as Judge Made Laws as distinct from Statute Law which is created by the parliament. SOURCE RULESThese Common Law Rules are equally important as Statute Law in determining location of income.

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12HWHSInterest income arises in the location where the debt contract is made.Rent income arises in the location where the property is situated.Royalty income arises in the location where the property giving raise to that income is registered. Dividend income arises where the Fund of Profits from which the dividend is paid, maintained or kept. Annuities arise in the location where the instrument relating to the annuity is made. Capital Gains arise in the location where the property giving rights to the capital gain is located.SOURCE RULES conSource Rules or Common Law Rules or Judge Made Laws

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13HWHSThe tax liability of a non-resident on profits and income arising in or derived from Sri Lanka consists of;

Profits and income under Section 2 (1) (b)Service rented in Sri Lanka.Property in Sri Lanka.Business transacted in Sri Lanka whether directly or through an agent.Interest on certain loan under Section 93Certain royalties under Section 94LIABILITY OF NON-RESIDENTS

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14HWHSSome of Source Rules (Common Law Rules) created problems for the tax administration in the most of countries. A concept called Statutory Modifications have been enacted by relevant parliaments as a remedy for such source rules which has an effect of modifying the Common Law Rules. The following provisions have been introduced in The Act to modify these Common Law Rule.MODIFICATION TO SOURCE RULESStatutory modification for business income under Section 84.Statutory modification for interest income under Section 93.Statutory modification for royalty income under Section 94.The Parliament of Sri Lanka has not intervened for other common law rules and therefore the common law rule for dividends, annuities and services remain unchanged.

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15HWHSUnder Section 2 (1) (b), service income arises in the location where services are rendered which can be treated as the source rule relating service.SERVICE INCOMEAn Australia case called Commissioner of Federal Taxation v Efstathakis (1979) 38 FLR 276 where Mrs. Efsthathakis was a Greek citizen was employed by Greek Government in media office in Australia. Tax authorities assessed her remuneration for tax as service income arising in Australia by a non-resident individual. The Australian Supreme Court held that she was liable for tax as income arose within the country or service rendered in Australia. Further court said, service income arises where the services are rendered and not where the salary is paid or where the contract of service is made. Efstathakiss case is important for Sri Lanka as Section 2 (1) (b) is similar to Australian Law.

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16HWHSProfession or vocation of actor, musician, athlete or acrobat is liable for tax under Section 96 (1) as;SERVICE INCOME conLiability of a Foreign Entertainer or Artiste Every person or partnership who or which makes a payment to any other person who; is not a citizen of Sri Lanka; and carries on or exercises the profession or vocation of an entertainer or artiste, in respect of services rendered by such other person in Sri Lanka in the course of carrying on or exercising such profession or vocation, shall deduct from such payment income tax at the rate specified in the Fifth Schedule to this Act.

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17HWHSA non resident person is liable to tax on profits and income arising in or derived from Sri Lanka whether directly or through agent. These words have the same meaning as trade exercised with United Kingdom in the their act. Therefore, the precedent of United Kingdom tax cases play a decisive role in ascertaining a tax liability of non-resident person in Sri Lanka.BUSINESS INCOMEIn addition to Judicial Precedents, the following important tests is very useful to decide whether the business is transacted in Sri Lanka or trade is being carried on within Sri Lanka.Where the contract is signed.Where the delivery is taken place.Where the price is paid.

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18HWHSBUSINESS INCOME conErichsen v Last (1881) 1 TC 351Grainger & Sons v Gough (1896) 3 TC 311Anglo Persian Oil Company Ltd. v CIT (1935) 1 CTC 92Ceylon Financial Investment Ltd. v CIT (1941) 1 CTC 234The first 2 English Cases where the source rule relating to business income came to be formulated and House of Loads has taken into account the place where the contract is made. In Grainger Sons v Gough, the revenue argued that sending price list by French wine manufacturer to UK agent is a offer. But court clearly pointed out that offer was made by UK customers and accepted by French wine manufacturer and therefore contact was made in France. Con..The source rule relating to trade or business can be found in following of cases where the facts are very clear cut.

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19HWHSBUSINESS INCOME conA judge said why they formulated the particular rule in this way saying, if you go by any other consideration like where the goods are delivered, where the payment is made that we make international trade is impossible. Example, a vehicle permit holder in Sri Lanka goes to Toyota Agent in Sri Lanka and place the order with them. The agent will transmit that order to Toyota Corporation in Japan which send the vehicle to the permit holder.

Is Japanese Company liable to pay tax in Sri Lanka on the profit that they made on that car?

They are not liable for tax in Sri Lanka because the contact is made in Japan. If we try to made them liable on the basis they are doing business here Toyota Corporation never send cars.

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20HWHSBUSINESS INCOME conBut the Sri Lankan Government cannot tolerate that principle as estates are in Sri Lanka. Therefore, the parliament in Sri Lanka enacted a rule which can be found in Section 84 and the same section there as Section 38 in the Income Tax Ordinance - 1932. Statutory Modification for Business IncomeThe source rule called business is transacted where the contract is made which created a problem for Sri Lanka from very beginning due to the most of tea estates are owned by companies in England. The practice was that time is all tea manufactured in Sri Lanka exported to head office in England on consignment and the sales take place at the London Tea Auction. The estate owner non-resident company can argue that the contracts are made in UK therefore the profits arises there is not liable to tax in Sri Lanka.

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21HWHSBUSINESS INCOME conUnder Section 84, where a non-resident person carries on any agricultural, manufacturing or other productive undertaking;

Sells any product of such undertaking outside Sri Lanka, orDelivery outside Sri Lanka,

Whether the contract is made within or outside Sri Lanka, the full profit arising from the sale in a wholesale market shall be deemed to be income arising in or derived from Sri Lanka. Statutory Modification for Business Income conIf such profit has been increased through treatment other than handling, blending, sorting, packing and disposal of the product outside Sri Lanka, the profit increased shall not be deemed to be income arising in or derived from Sri Lanka.

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22HWHSBUSINESS INCOME con..Where any such product is not sold in a wholesale market, or is not sold at all, such person shall be deemed to derive profits from Sri Lanka within the meaning of Section 2 of The Act.

Such profits shall be deemed to be not less than the profits which might have been obtained, if such person had sold such product wholesale to the best advantage. Section 84 is a example where the parliament in Sri Lanka interfered in order to modify the source rule relating to business income. Otherwise the profit earned by non-resident companies in UK goes untaxed.Statutory Modification for Business Income con

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23HWHSBUSINESS INCOME con..Under Section 80, goods manufactures outside Sri Lanka, the liability of a non-resident person from sales is limited to;

The wholesale profits, if the sale was by wholesale, which might reasonably be expected to be made by a merchant selling the property by wholesale.

The retail profits, if the sale was by retail, which might reasonably be expected to be made by a merchant selling the property by retail.This provision has the effect of excluding the profits attributable to manufacture which does not arisen in Sri Lanka and restrict the profits arising from the sale of goods in Sri Lanka.Products Manufactured Outside Sri Lanka

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24HWHSINTEREST INCOME Under Common Law Rule, interest income arises in the location where the debt contract is made. The statutory modification has been enacted for this rule under Section 93 in The Act which stipulates;Where interest is payable to a non-resident person on a loan obtained from such person and the interest on such loan is borne;

directly or indirectly by a person resident in Sri Lanka; orby a non-resident person, where the amount of such loan or part thereof has been brought to or used in Sri Lanka,

Such interest shall be deemed to be profits and income arising in or derived from Sri Lanka.Statutory Modification for Interest Income

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25HWHSINTEREST INCOME conExample: If a Sri Lankan person goes abroad and takes a loan from a person outside Sri Lanka after signing the agreement outside the country. Then he comes to Sri Lanka and pay interest for that foreign person in terms of the agreement.

With regard to interest income, the Common Law Rule is interest income arises in the location where the debt contract is made. The outcome is the foreign person is not liable to tax in Sri Lanka under Common Law Rule. This rule has been modified by Section 93 in the present act. Now even though the debt contract is made outside Sri Lanka, the interest income liable for income tax if the interest is borne by a person resident in Sri Lanka.Statutory Modification for Interest Income con

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26HWHSROYALTY INCOMEThe Common Law Rule relating to royalty income is the income arises in the location where the property giving raise to that income is registered. Similarly as above, Section 94 enacted to cover royalty income received by a non-resident person. The particular section stipulates as;Where royalties are;

borne directly or indirectly by a person resident in Sri Lanka; ordeductible under Section 32,

Such royalties shall be deemed to be profits and income arising in or derived from Sri Lanka.Statutory Modification for Royalty Income

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27HWHSRENT, GROUND RENT, etcUnder Section 95 (1) in The Act;

Where any person or partnership in Sri Lanka pays or credits to any person or partnership out of Sri Lanka, any sum falling due as;

Interest on debentures, mortgages, loans, deposits or advances; or

Rent, ground rent, royalty or annuity which is payable either in respect of property in Sri Lanka or out of income arising in Sri Lanka, Whether such sum is due from him or from another person or from a partnership, he shall be entitled to deduct income tax at the appropriate rate specified in the Fourth Schedule to The Act.

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28HWHSTAX PAYABLE BY NON-RESIDENTS COMPANIESUnder Section 62 (1), a non-resident company shall be liable to pay income tax for any year of assessment is consist of;A sum equal to the amount calculated at the rate specified in the Second Schedules in The Act.

Where there are remittances of such company in that year of assessment, a sum equal to 10% of the aggregate amount of such remittances by such company.Note: Normally a resident company is required to pay Dividend Tax on their gross dividend declared. But this Dividend Tax is replaced by Remittance Tax at the same rate 10% for a non-resident company on their gross remittances. Deemed Dividend Tax is not applicable for non-resident companies.

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29HWHSAny sums remitted abroad or retained abroad out of the profits which is chargeable with income tax.

Any sum retained broad out of sale proceeds of any product exported.

Any product exported and not sold in the wholesale market or not sold at all, the deemed profit of sale of such product in wholesale. Under Section 62 (2) remittances means;TAX PAYABLE BY NON-RESIDENTS COMPANIESThe remittances do not include;Any dividend paid by a resident company to another non-resident company.

Any remittance of expenses or expenses incurred abroad which are claimable in arriving at the profits and income.

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30HWHSBut a sum equal to the lower amount can be deducted as head office expenses in terms of Section 27 (1) as;Amount of actual expenses, orAmount equal to 10% of profits or income.In the case of a non-resident company, head office expenses are not allowed as a deduction in terms of Section 26 (1) (w) in The Act.HEAD OFFICE EXPENSESBut again, the effect of Section 27 (1) is overruled by Section 97 (Effect of Agreements for Double Taxation Relief) by which head office expenses are allowed to deduct if such expenses are attributable to agencies, branches or establishments in Sri Lanka. Note: Above deductions should be made, subject to other provision of The Act. Examples are restriction of advertising and capital nature expenditure.

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31HWHSInstrumentality rule is recognized as a principle of corporate law which permits a court to disregard the corporate existence of a subsidiary company when it is operated solely for the benefit of the parent company which controls and directs the activities of the subsidiary. According to this rule, a company is treated as a subsidiary if it is controlled to a great extent by another company. INSTRUMENTALITY RULEAccordingly, a non-resident person is liable to tax on the profits and income arising in or derived from Sri Lanka, if such profit arose through the Instrumentality of a person in Sri Lanka although the actual sales and the legal transactions were finalized outside Sri Lanka.

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32HWHSThis Rule of Instrumentality has been recognized in Section 80 as where a person in Sri Lanka, acting on behalf of a non-resident person;Effects or is instrumental in effecting any insurance, Sells or disposes of or is instrumental in selling or disposing of any property,

the profit arisen from the insurance, sales or disposals are deemed to be derived by the non-resident person from business transacted by him in Sri Lanka. The person who acts on his behalf is deemed to be his agent.INSTRUMENTALITY PROVISIONThe purpose of Section 80 is to ascertain non-residents who is acting through agent in Sri Lanka in selling or disposing insurances or properties, although legally contacts and transaction are made outside Sri Lanka

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33HWHSINSTRUMENTALITY PROVISION conIn the case of Chivers Sons Ltd v CIT (1937) 1 CTC 124, the court held that non-resident company was liable to tax on the profits arose from Sri Lanka as a result of local company F. X. Perera & Sons brought about the transaction. But in the case of Anglo Persian Oil Company Ltd. v Commissioner of Income Tax (1935) 1 CTC 92, the court held that;The company in UK not doing any business in Sri Lanka.Local company was not instrumental in bringing about the transactions.The following factors must be satisfied to make a non-resident liable.The sale must be to a person in Sri Lanka.The goods must be brought to or property must be in Sri Lanka.The goods must be the property of the non-resident person.

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34HWHSIn Anglo Asian Oil Company case, Justice Akbar expressed his views as;INSTRUMENTALITY PROVISION con The sale or dispose when it refer to the person in Sri Lanka, means a definite legal act and does not include a mere delivery by an agent in Sri Lanka of goods sold in pursuance of a contract made outside Sri Lanka. Note: The sale or dispose has to be brought about through the instrumentality of a person in Sri Lanka acting on behalf of a person outside Sri Lanka.

If a non-resident person sells his property directly to buyer in Sri Lanka and not through the instrumentality of an agent, then no tax liability will be arisen on the profits made by that non-resident person.

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35HWHSA broad definition has been provided for the term agent under Section 217 which reads as;LIABILITY OF LOCAL AGENTSAgent, in relation to a non-resident person or to a partnership in which any partner is a non-resident person, includes; The agent, attorney, factor, receiver or manager in Sri Lanka of such person or partnership; andAny person in Sri Lanka through whom such person or partnership is in receipt of any profits or income, arising in or derived from Sri Lanka.Who is a Agent?

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36HWHSUnder Section 81, a non-resident person shall be assessable either directly or in the name of his agent in respect of all his profits and income arising in or derived from Sri Lanka, whether such agent has the receipt of the profits or income or not.LIABILITY OF LOCAL AGENTSPersons Assessable on Behalf of a Non-Resident PersonThe income tax so assessed whether directly or in the name of the agent shall be recoverable in the manner provided for in The Act, out of the assets of the non-resident person or from the agent. Where there are more agents than one, for they may be assessed jointly or severally in respect of the profits and income of the non-resident person and shall be jointly and severally liable for income tax thereon.

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37HWHSTYPE OF TRANSACTIONSTransactionRemarksConsignment AccountGoods are sent on consignment basis then the contract of sales takes place in Sri Lanka. Profits are clearly liable.TendersWhere tenders are made by a non-resident to the government through an agent, the non-resident is liable to tax. If the tenders are made directly to principal, no tax liability.TransshipmentGoods in transshipment are not liable to tax.Indenting AgentCommissions received by indenting agents are liable to tax. Also profits of non-resident person is liable to tax.Buying House or ShippersCommissions received are liable to tax. No liability to non-resident manufacturer or merchant. However, if the Buying House or Shipper acts as an agent of non-resident, the profits will be liable to tax in Sri Lanka.

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38HWHSWhere the Commissioner General is of the opinion that the correct amount of the profits of a non-resident person arising in or derived from Sri Lanka cannot be readily ascertained for the reason that such person is unable to furnish;

The fuller or further returns or fuller or further information referred to in Section 106 (12), or

The documents or the other documents referred to in Section 106 (13), relating to his trade or business,

If such non-resident person makes a declaration of that inability, the Commissioner General shall ascertain such profits on the basis of fair percentage of the turnover at minimum 6%. PROFIT AS A PERCENTAGE OF TURNOVERNote: Section 106 (12) & (13) - An Assessor or Assistant Commissioner give notice in writing to any person asking for further information and documents.

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39HWHSUnder Section 82 (1) (a), a person is closely connected with another person, where the Commissioner General is satisfied that such persons are;

Substantially identical or

Ultimate controlling interest of each is owned or deemed to be owned by the same person or persons.CLOSELY CONNECTED PERSONSUnder Section 82 (1) (b) , the controlling interest of a company is deemed to be owned by the beneficial owners of its shares, whether held directly or through nominees. Shares in one company held by or on behalf of another company deemed to be held by the shareholders of the last-mentioned company.Who are Closely Connected Persons?

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40HWHSExample: A person in Sri Lanka and another non-resident person arrange their affairs in a way where the person in Sri Lanka receives little or nothing of the profit of the business and pay minimum tax or no tax at all. CLOSELY CONNECTED PERSONS conSection 82 (2) and 82 (3) of The Act intended to catch them and seek to make liable the profit of the non-resident who is doing business with a resident person deemed closely connected. In a situation where the Commissioner General is of the opinion that such persons are closely connected, the business is deemed to be carried on Sri Lanka and the non-resident is chargeable and the resident person in Sri Lanka is considered as his agent. In that case, all the provisions of The Act shall be applied accordingly under Section 82 (2).

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41HWHSUnder Section 97 (1) (a), where the Parliament of Sri Lanka approves any Double Taxation Avoidance Agreement (DTAA) with a government of any other territory for the purpose of affording relief from double taxation in relation to income tax under Sri Lanka Law and any taxes of a similar character imposed by the laws of other territory, such agreement shall provide for;RELIEFS FOR DOUBLE TAXATIONRelief from income tax.Determining the profits or income attributable to non-resident persons and their agencies, branches or establishments in Sri Lanka.Determining the profits or income attributable to resident persons in Sri Lanka.Exchange of information.Assistance in the recovery of tax payable.

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42HWHSThe reliefs will be granted under Credit Method and the credit so granted on profits or income arising from any source, shall not exceed the amount of Sri Lanka tax payable in respect of that profits or income. RELIEFS FOR DOUBLE TAXATION conIncome shall be calculated in accordance with the provisions of The Act relating to the ascertainment of assessable income, but shall not include any sum payable by way of interest, annuity, ground rent or royalty. Sri Lanka Tax means the amount of income tax payable under The Act before deducting any reliefs under Section 97. But does not include tax on any sum payable, by way of interest, annuity, ground rent, or royalty out of the income in respect of which the tax is charged.

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43HWHSTAX RATESLiability to TaxRateThe Profits or income arising in or derived from Sri Lanka to any person who is not a citizen of Sri Lanka carrying on the profession or vocation of an entertainer or artiste. Section 96 12%Interest arising in or derived from Sri Lanka to a non-resident person or partnership outside Sri Lanka on loan granted to a person in Sri Lanka. Section 3815%Royalties received by a non-resident person or partnership from any person in Sri Lanka and is deemed to be arisen or derived from Sri Lanka. Section 3915%The profits and income derived from outside Sri Lanka by any individual who has been a non-resident of Sri Lanka and who arrives and stays in Sri Lanka. Section 15Exempt

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44HWHSTAX RATES conLiability to TaxRateAny royalty received by a non-resident person from a company with which an agreement has been entered into before April 1, 2004 by the Board of Investment of Sri Lanka. Section 13 (y) ExemptInterest, annuity, ground rent or royalty received by a non-resident person from outside Sri Lanka.Exempt

Any dividend received by a non-resident company from a resident company which has deducted Tax under Section 65 (1). The non-resident company is not entitled to a refund of tax so deducted.Exempt

Note: A non-resident person or partnership will be liable to tax as resident persons and partnerships in all other cases as stipulated in The Act.

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45HWHSABOUT TAX "Little else is requisite to carry a state to the highest degree of opulence from the lowest barbarism but;Peace,Easy Taxes, andA Tolerable Administration of Justice.All the rest being brought about by the natural course of things.Adam Smith

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46HWHSTHANKING YOU FOR WATCHINGHARISON SAMARATUNGACTA, ATII, MAAT, B. Sc. (B. Ad) Sp, HNDC

Chartered Tax Advisor andAuthorized Representative15th December 2015Please mail your feedback to: taxoffice7878@gamil.com

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On Sacred GroundYanniIf I Could Tell You, track 12002Instrumental431315.9eng - , AG# AD806261