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(c) Soda Crush is contemplating the following investments in the coming year: Purchase of office building as the company finds it challenging to manage
(c) Soda Crush is contemplating the following investments in the coming year: Purchase of office building as the company finds it challenging to manage their real estate needs using rental premises as their business is expected to grow with the exponential growth in demand for their e-games in recent years. The building will be used primarily for the business and any excess space will be rented out if there is no immediate need for the space. The company has been offered 10% equity investment in King Entertainment Inc. ("King"), a company tax resident in Country Z which has a headline tax rate of 15%. Country Z does not impose dividend withholding tax. King is an up-and-coming e-game developer and the money raised through the current equity injection exercise is to finance the further growth and development of King before it embarks on an initial public offering ("IPO), expected to take place in the next 4 to 6 years. Meanwhile, King is projected to be highly profitable and dividends are expected to be paid to its shareholders annually. Soda Crush is considering financing the purchase of the above investments through: (i) (ii) Share capital injection Bank loans Partial disposal of shares in Queen, a public listed company in Country Y. The investment has been held since financial year 2016 and it was purchased for long-term holding purposes as the dividend returns were deemed to be attractive. Soda Crush did not dispose of any of its shareholdings when Queen was listed on the stock exchange. Its current shareholding is 10% and Soda Crush does not intend to sell more than 5% of its current holdings. Explain the Singapore income tax implications of each of the above mode of financing. You are to address the income tax implications of the receipt of funds from each mode as well as the expense or outlay in relation to each mode. (25 marks) Discuss the merits or disadvantages of using each mode of financing to purchase the proposed investment. (17 marks) (iii) Provide your recommendations of the most tax efficient way in which Soda Crush should finance each of the above investment and explain the basis of your recommendations. (8 marks)
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