In the course of her tax career, Fabiola has gained an understanding of various industries/sectors such as telecommunication, mining, oil and gas, manufacturing and financial services. She has endeavored to undertake complex tax analysis with the aim of identifying key client issues that require value addition. Specific experience is set out below:

Tax advisory

• Fabiola has advised on tax implications and compliance requirements for various transactions carried out by companies in various industries. This includes:
• Advisory on restructuring and reorganization of group entities specifically on potential tax implications of mergers and acquisitions (purchase of shares or assets), refinancing arrangements and setting up of shared service centers;
• Advising on tax implications on day-to-day arrangements of businesses in Tanzania including review of contracts and advising on potential exposures or tax saving opportunities. With respect to Customs, she has provided assistance to clients that ranges from queries relating to pre-importation to addressing matters raised by the Tanzania Revenue Authority (TRA) during their post clearance audits.
• Carrying out tax health checks and due diligence assignments to ensure compliance with the law and recommending corrective measures; and
• Conducting customised tax training.

Dispute resolution

• This forms a significant part of Fabiola’s experience and through numerous audits conducted by the TRA, she has had an opportunity to assist clients in handling the audit queries, preparation and filing of notices of objection and related correspondences with the TRA and filing of appeals with the Tanzanian Appellate Bodies. At times, she has appeared as a subject matter expert during hearing of these appeals.

Tax Compliance

• Fabiola has an understanding of compliance requirements in respect of various tax returns such as Corporate Income Tax, Withholding tax, Payroll taxes (including PAYE, SDL, WCF and Pension contributions), Value Added Tax, Excise duty and local levies such as Service levy.
• With regards to Zanzibar, Fabiola has an in-depth understanding of non-union taxes and levies such as VAT, Excise duty and Stamp duty, that are administered by the Zanzibar Revenue Board (ZRB).

Participation in tax reform on behalf of business associations

• Fabiola has been involved in presenting tax challenges facing certain industries and proposing adoption of best tax practices to the Ministry of Finance (through the Task Force for Tax reform) and the Parliamentary National Budget Committee. For instance, Fabiola was actively involved in pre-budget lobbying for the removal of Value Added Tax on ancillary transport services in respect of transit goods and removal of a local levy (Railways Development Levy) on supply of Jet-A1 fuel, following which amendments were made by the Government to implement the proposed changes. Furthermore, Fabiola has actively assisted the communications industry in achieving a centralized collection system for payment of Service Levy to avoid potential disputes with Local Government Authorities.
• In this process, Fabiola has gained considerable knowledge on how these industries operate and has had an opportunity to appreciate the challenges faced in terms of tax policies and how the Government may be engaged to resolve them.