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Question 1 Ricoh Group is a group that specializes in the manufacture of 3D printers

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Question 1 Ricoh Group is a group that specializes in the manufacture of 3D printers. Its group structure is as follows: Ricoh Ltd 85% 70% 100% 100% 90% Co B Co C Co D Co E Co F % refers to ordinary shareholdings. The remaining shareholdings are held by Mr Nelson, who normally resides in Country A. There have been no changes to the shareholdings of the companies since their respective dates of incorporation. Ricoh Ltd Ricoh Ltd manufactures 3D printers and it has its sole manufacturing plant in Country A. Ricoh Ltd was incorporated and tax resident in Country A and its sole shareholder is Mr Ricoh. Ricoh Ltd sells its manufactured 3D printers to related companies. Co B Company B (Co B) is incorporated and tax resident in Singapore. Co B acts as the Group Finance company and sources for cost-efficient loans from financial institutions located in Singapore as well as other countries. Funds from the loans obtained by Co B will be on lent to Co D, Co E and Co F for use in their businesses in exchange for interest. Co C Company C (Co C) is incorporated and tax resident in Singapore. Co C provides various services to only companies in Ricoh group. These services include human resource, accounting and IT support services. In addition, Co C provides assistance in procuring raw materials as well as technical services in relation to the repair of 3D printers to Ricoh Ltd. Co C will source for cost-efficient raw materials suppliers for Ricoh Ltd which will purchase the raw materials from these suppliers. All mentioned services are performed by the employees of Co C. Co D Company D (Co D) is incorporated and tax resident in Country D. Co D is the legal and economic owner of the brand trade mark of 3D printers manufactured by Ricoh Ltd. Co D licenses the brand trade mark to Co E and Co F for an annual royalty fee. Co E Company E (Co E) is incorporated and tax resident in Country E. Co E purchases 3D printers from Ricoh Ltd and resells them to customers in Country E and other countries. Co E has a local liaison person in other countries where the customers of 3D printers are located.


Co F
Company F (Co F) is incorporated and tax resident in Country F. Co F purchases 3D printers from Ricoh Ltd and resells them to customers in Country F. Available tax information of the various countries are as follows: Country A Country D Country E Country F Corporate tax rate 15% 10% 25% 20% Domestic withholding tax for interest payments to non residents 5%. 10% 15% 20% Domestic withholding tax for service fee payments to non residents 10%. 10%. 20%. 15% Domestic withholding tax for royalties payments to non residents 7%. 8% 12%. 16% Required: You are the Group's tax consultant. You have been asked to examine and analyse the current structure and business operations of Ricoh Group and make a report to management advising on the potential tax implications in the various countries including compliance with Singapore transfer pricing guidelines and documentation requirements. You are to use the core principles and concepts underpinning international tax planning for the report. In the report, you should also identify relevant information not available in the scenario and appraise the corresponding income tax implications based on assumptions regarding this outstanding information. You should not assume that there are transactions other than those mentioned in the case scenario. You are not required to propose any changes to the current structure and business operations of Ricoh Group. You also do not need to address other taxes such as GST/ VAT and personal income taxes in your answer.