DRAWING – INTM255050D

Assumptions

All subsidiaries are 100% held.

All holding companies satisfy the requirements in ICTA88/SCH25/PARA6(1)(a) and (b) (business establishment and effective management).

Trading 1 – 8 are carrying on exempt activities.

The main business of Holdcos is as described.

Holdco 4

The main business of Holdco 4 is to hold the shares in Trading 6 – 8 which are all resident in the same territory as Holdco 4.

Holdco 4's gross income is as follows

Dividends from Trading 6 – 8 90
Bank interest 10
100

Since 90% of Holdco 4's gross income is derived from its trading subsidiaries carrying on exempt activities Holding 4 is a local holding company.

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