[jaemx]

Asia Geomancy Online Portals (Hong Kong) Limited (AGOP) was established in Hong Kong on 1 January 2019 for the purpose of researching and developing new technologies for providing online geomancy advice to clients. Currently, all geomancy consultancy works are provided by renowned geomancy masters based in Hong Kong. On 1 July 2019, Asia Geomancy Online (Singapore) Pte Ltd (AGOS) was incorporated in Singapore. AGOP owns 80% of AGOS. The purpose of establishing the new company in Singapore was to eventually hold all intellectual property (IP) in the venture. AGOP would meanwhile provide a number of services to AGOS, and these would include the following: Right to use the technologies developed by AGOP Technical & Operational Services (operating the websites in Hong Kong) Management Services (the Group’s senior management are employed by AGOP and live in Hong Kong) AGOS will pay monthly retainer fees to AGOP for the above services, also from 1 July 2020. It is also contemplated that AGOP will soon transfer all IP resulting from its R&D work to AGOS. This includes all IP resulting from: The work done prior to the incorporation of AGOS during AGOP’s first 15 months of operation; and The work done on an ongoing basis after the incorporation of AGOS. There will inevitably be some transfer of “know how” as well. (a) Advise AGOS on all Singapore tax implications arising from the monthly retainer fees payable to AGOP for Year of Assessment 2021, assuming separate contracts for the various types of services may be invoiced separately. AGOP will transfer all of its technology to AGOS and all related IP in exchange for a one-off payment. Advise AGOS on the Singapore tax implications arising from this payment, assuming it wants to optimise its tax position.

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