Voluntary Tax Disclosure Programme

"It is not in dispute that the VTDP was time bound and covered the period 2015-2020.The Respondent’s Assessment being for the period 2019-2022 and the Appellant having taken advantage of the programme, it means therefore the period covered under the program was 2019-2020 which then leaves the disputed period as 2021-2022.Having also confirmed the applicable WHT rate for non-resident entities outside the VDTP period to be 20%, the Appellant cannot assume the programme covered the period up to 2022 and hide behind the Respondent’s approval which according to Section 37D of the TPA is specific."