Briefly state, with reasons, whether or not you consider the below mentioned companies

to be a public company for tax purpose.

(i) APL is a company incorporated under the Companies Act 2017 and is not listed on any stock

exchange in Pakistan. 58 per cent of the shares in APL are held by KFG Ltd, a company

incorporated in United States. United Sates holds 95% of the shares in APL Ltd

(ii) GGH Limited is a public company incorporated under the Companies Ordinance,1984 whose

shares were traded on the Pakistan Stock Exchange from 01 August 2017 until 29 June 2018 on

which date the company was delisted on the exchange.

(iii) The Provincial Government of KPK holds 50% of the shares in JKK Ltd, a public company

under the Companies Act 2017. JKK Ltd is not listed on any stock exchange in Pakistan.

(iv) FFC is a public company under the Companies Act 2017. 41% of the shares are held by the

Federal Government, 50% by the Government of Saudi Arabia and 9% by the individuals and

group companies. FFC is not listed on any stock exchange in Pakistan.

(b-ii) Gazda Inc, a public company incorporated under the law of the United States relating to the

incorporation of companies, has been operating in Pakistan for over 50 years. The control and

management of the Pakistan branch for the accounting year ended 31 December 2017 was situated

wholly outside Pakistan.

Required: Briefly state, with reasons whether Gazda Inc. will be assessed as a company for

Pakistan tax purposes for the relevant tax year.