a) Kingston Food Industries is a company resident in country Z. The company is planning to incorporate a wholly owned subsidiary in Singapore, Singston Co Pte Ltd with a paid-up capital of $100,000. As Singston Co Pte Ltd is planning to expand its food processing industries in Singapore, it plans to borrow $1 million from its parent company, Kingston Food Industries. The interest is payable on 31 December every year. The financial controller has advised the consequences of S45 of SITA to the group controller of Country Z. But the group controller of Country Z has asked for your professional advice on the following: i) The application of the provisions of S45 of SITA for the interest payments; ii) The appropriate WHT (withholding tax) rate and the consequences of non-compliance of 545 inclusive of penalty of late payment, if any; iii) Assume the first interest payment is $100,000 and is paid on 30 April of the following year to Kingston Inc. Advise on the due date of withholding tax and compute penalty if any; b) Kingston is planning to send its senior manager, Mr David Thompson, to assist in the management of Singston for the first 6 months of its operations. Mr Thompson will arrive on 16 November 2021. Mr Thompson is born and is a citizen of Country Z. There is NO tax treaty between Singapore and Country Z. Discuss the tax implications of the above for Mr Thompson i) YA 2022 and YA 2023 - if he stays for 6 months only; ii) YA 2022 and YA 2023 - if he stays till 31 May the following year a) Kingston Food Industries is a company resident in country Z. The company is planning to incorporate a wholly owned subsidiary in Singapore, Singston Co Pte Ltd with a paid-up capital of $100,000. As Singston Co Pte Ltd is planning to expand its food processing industries in Singapore, it plans to borrow $1 million from its parent company, Kingston Food Industries. The interest is payable on 31 December every year. The financial controller has advised the consequences of S45 of SITA to the group controller of Country Z. But the group controller of Country Z has asked for your professional advice on the following: i) The application of the provisions of S45 of SITA for the interest payments; ii) The appropriate WHT (withholding tax) rate and the consequences of non-compliance of 545 inclusive of penalty of late payment, if any; iii) Assume the first interest payment is $100,000 and is paid on 30 April of the following year to Kingston Inc. Advise on the due date of withholding tax and compute penalty if any; b) Kingston is planning to send its senior manager, Mr David Thompson, to assist in the management of Singston for the first 6 months of its operations. Mr Thompson will arrive on 16 November 2021. Mr Thompson is born and is a citizen of Country Z. There is NO tax treaty between Singapore and Country Z. Discuss the tax implications of the above for Mr Thompson i) YA 2022 and YA 2023 - if he stays for 6 months only; ii) YA 2022 and YA 2023 - if he stays till 31 May the following year
