Q.2 (a). 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.

(b). Explain the residential status of the following persons for the tax year 2018, by stating whether individual is a resident or resident person according to the criteria laid down in the ITO 2001. (i) Mr. Raza is working as Director Operations in the Ministry of Tourism. On 15 July 2017 he was posted to Pakistan Embassy in Italy for two years. (ii) Anderson LLC was incorporated as limited liability company in UK. The control and management of its affairs was situated wholly in Pakistan. However, with effect from 01 November 2017, the entire management and control was shifted to UK. (iii) On 01 February 2018, Mr. Sameel was sent to Pakistan by his UK based company to work on a special project. He left Pakistan on 23 August 2018. (iv) BBL is a non-listed public company incorporated under the Companies Ordinance, 1984. All the shareholders of the company are individuals. The control and management of affairs of the company during the year was outside Pakistan. (v) Mr. Salman a property dealer in USA came to Pakistan on 01 February 2017. During his stay up to 02 August 2017 in Pakistan, he remained in Peshawar up to 30 June 2017 and thereafter till his departure from Pakistan, in Quetta. Assume that Commissioner has granted him permission to use calendar year as special tax year. (c). Define salary according to ITO 2001 and list down the various components/perquisites to be included while calculating the income under the head of salary.