Assume that Warm and Frosty Pet Mats Pty Ltd has been operating for more than 5 years. Over that time the Company has improved its position in the market and has reasonable profit growth over the five-year period. Shannon lists the company on the Australian Stock exchange in 2022. He retains 20% shareholding in his own name. When he moves overseas to work for Sparkys R Us in Malaysia, he realises that any unfranked dividends received from Warm and Frosty Pet Mats Ltd will incur 15% withholding tax if Shannon is found to be a foreign resident for tax purposes in Australia. Shannon investigates whether this would change if a company structure incorporated in Malaysia held the shares and realises that the 15% withholding tax is relevant to any type of Malaysian tax entity. During his investigations Shannon did find that Australia has a double tax agreement with Germany. Any dividends received from an Australian incorporated company to a tax entity in Germany will also result in lower withholding tax of 15%. However, if the dividend owner is a Company who holds more than 10% of the shareholding of the Australian company the maximum withholding would be 5% of the