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Eno Mary Ltd is a resident company in Ghana, Mama Rho Ltd acquired 6 2 % of the underlying ownership of the company. Following the

Eno Mary Ltd is a resident company in Ghana, Mama Rho Ltd acquired 62% of the
underlying ownership of the company. Following the acquisition arrangement, a loan facility
of GHS10 million was secured by Eno Mary Ltd from Mama Rho Ltd. The interest rate
agreed was 4% more than the average of 25% being charged. The interest paid in 2021 was
GHS2.5 million.
Mama Rho Ltd is exempt from tax on all its income.
The following is the capital structure of Eno Mary Ltd for 2021 year of assessment:
Details January 1,2021 December 31,2021
GHS GHS
Share Capital 1,000,0001,200,000
Retained Earnings 200,000250,000
Revaluation Reserves of assets 100,000100,000
Required:
(i) Compute the tax implication of the above arrangement and provide a brief explanation of

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