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A taxpayer wishes to incorporate a single-member limited company and asks whether the remuneration they receive for their work will be a deductible expense for the company. The DGT rules that such payments are deductible, provided they meet the requirements for accounting entry, accrual, correlation with income, and substantiation, and are clearly distinguished from administrative duties.
Question raised 1) Whether the remuneration received by the natural person for their work in the limited company would be a tax-deductible expense for the company.
Expenses for partner remuneration for work performed are tax-deductible in Corporate Income Tax if they meet the conditions of accounting registration, accrual basis, and documentary justification. Such expenses must constitute consideration for functions other than those of a director. Furthermore, transactions between related parties must be valued at their normal market value.
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