You are tax adviser to a UK company, Thomas Plc that manufactures advanced medical equipment for export to the major markets in the EU, USA, Japan and China. The newly installed Finance Director of Thomas Plc has contacted you as she has some concerns about certain current intra-group trading arrangements within the group. Thomas Plc has a wholly owned subsidiary, Tuohy Limited that is located in the Republic of Ireland. Thomas Plc has been exporting goods to Tuohy Limited at prices that are lower than the market prices and this results in lower tax liabilities the UK has a Corporation Tax Rate of 19% in 2020/21 and this is significantly higher than the company income tax rate in the Republic of Ireland. The Finance Director has also asked for your opinion on a possible relocation plan of the group that would involve establishing a new holding company called Thomas Holdings Plc to be incorporated and head-officed in Dublin in the Republic of Ireland to take over Thomas Plc currently based and head-officed in London. Thomas Holdings Plc's board would comprise the same directors as Thomas Plc and you are asked what would be the position if six of the eight directors who currently sit on the board of Thomas Plc continued to live in the UK and the board meetings of the new Thomas Holdings Plc continued to take place in London. Required: Write a letter to the Board of Thomas Plc outlining the UK and wider tax position relating to the following: a) The intra-group trading and pricing arrangements outlined above. (14 marks) b) The possible re-establishment and relocation of the holding company as outlined above. (11 marks) (25 marks)