Background:

Mohamed Akhtaruzzaman (Akhtar) aged 37 and Kathryn Aybar-Chiew (Kat) aged 34 are the directors of a logistics company in Singapore. The name of the company is AK Transport Pte Ltd (AKT). The shareholders are the company are private companies owned by Akhtar and Kat. Akhtar's private company owns 65% of the shares and Kat's private company owns 35%

The company has 35 staff and is located in an industrial estate near Changi Airport. The company has been in existence for 5 years.

The company as well as the director ands their immediate family are all clients of the firm.

The income sources for the company are from sales received from local customers as well as international customers. Two of their major customers from overseas are Amazon and a new company called Temu.

The company offers a transport solution and a storage facility for clients.

Being a logistics company it needs to maintain relationships with many overseas countries and staff are sometimes required to travel overseas to maintain contacts with existing customers and also find new customers.

Given the uncertainty in the global economy and the threat of global recession the company had had to had to undertake various steps to increase revenue as well as reduce costs.

Akhtar and Kat have requested a meeting with Jonathan to discuss various tax and accounting, corporate law issues.

Jonathan is away in Western Sumatra on business for another client of KT and cannot attend the meeting. He will not be back until Monday 14 March 2024. Therefore, he has requested the senior manager (Sunil) to organise the meeting with the clients. He has asked you:

1. to sit in on the meeting and
2. take notes on the issues raised

When Kat was in Saudi Arabia visiting the investor, she was told that the tax rate was nil in Saudi Arabia and AKT was crazy to pay tax at 17% in Singapore on the profits.

The Saudi Arabian investors suggested a scheme or arrangement where fictitious invoices could be created to move the profits to Saudi Arabia, pay no tax and the Saudi Arabian company would "lend" the money back interest free to AKT.

Issues they seek advice on:

1. Advise the directors and the company if the above proposal is a valid transaction that AKT could enter into or are there specific provision that would prevent AKT doing the above?