Construction and financing of the construction of a 500-room hotel and a conference hall 1.MMSB will be entering into a contract with its holding company, Marconi SpA (MSpA), a non-tax resident, to undertake the hotel project. In spite of the uncertainties due to the Covid-19 pandemic situation, they foresee that the project can commence on 1 February 2022 and complete by the end of 2025. Mr Jest, the Chief Engineer, will lead in supervising the Project with the assistance of a few engineers from MSpA who will be seconded to MMSB. 2. The total contract fee is RM800 million. It includes equipment, materials, professional services which include services provided by MSpA in Italy. MMSB will make four quarterly payments in a year to MSpA, with the first payment due on 31 March 2022.

3. To finance the project, MMSB will arrange to get a loan of RM200 million at an interest rate of 4% per annum from a related company, Marconi Australia Ltd. (MAL).

Question: What is the tax implication on MMSB, MSpA and MAL based on transfer price and withholding tax. Tax implications relating to the construction of the hotel and its financing including tax compliance and any mitigating measures for tax efficiency. (based on Malaysia Tax)