Investor Presentaiton
TMK "tax qualifying" conditions
Conditions to be a "tax qualifying" TMK continued
10. The TMK does not have any assets other than the properties or
other specified assets disclosed in its Asset Liquidation Plan.
11. Where the TMK obtains a loan, this should only be from Tax
QII and should not be from specified equity holders.
Note that the "tax qualifying" TMK can also obtain loan
financing in addition to debt financing, but this must
again come from a Tax QII.
NOTE:
Distributable
profit
=
Distributable profit
calculated based on
accounting principles
(Note c)
less
5% of
outstanding
bonds value
(Note a)
less
Retained earnings
carried forward from
prior years
plus [X] (Note b)
Note (a): The outstanding bond value means the balance of the bond at the end of the financial year.
Note (b): [X] = {Redemption amount of bonds during the financial year (if any) less: Depreciation amounts that are deductible for corporate tax purposes} x 2
If [X] is a negative amount, (✗] is treated as zero. That is to say, if the total amount of bonds redeemed during the financial year does not exceed the
depreciation expense recognised by the TMK during the financial year, this adjustment is not required.
Also, if the Specified Assets (being those assets identified in the Asset Liquidation Plan) are disposed of, or the TMK issues bonds or promissory notes
(including loans) during the financial year, amounts acquired from the disposition or issuance and applied to the bond redemption are deducted from the above
redemption amounts of the bonds.
Note (c) If there is any loss carried forward from prior years and/or any current year impairment loss, the total amount of the loss carried forward from prior
years and 70% of the current year impairment loss is deducted from the accounting income before tax.
KPMG
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Document Classification: KPMG Confidential
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