scholarly journals TAX REASONS FOR ESTABLISHING A HEADQUARTER COMPANY

Obiter ◽  
2021 ◽  
Vol 32 (1) ◽  
Author(s):  
Thabo Legwaila
Keyword(s):  

Headquarter companies are generally interposed between the ultimate holding company and the operating subsidiaries of a group of companies. The functions of a headquarter company are mainly to manage investments and to centralize the income of the group prior to remittance to the ultimate holding company. Therefore, generally, the rationale for setting up a headquarter company is based on economic and structural needs of the group in which the headquarter company is to be set up. However, it is also common cause that the decision to set up a headquarter company is, more often than not, influenced by the need to take advantage of tax instruments available in the particular jurisdiction. This allows the group to reduce its overall tax liability and therefore increase its after tax earnings.

1994 ◽  
Vol 33 (3) ◽  
pp. 223-256 ◽  
Author(s):  
Newton E. Key

In December 1655, four stewards for the Worcestershire feast wrote to the eminent divine Richard Baxter regarding possible worthy charities for money collected at their recent London feast. Baxter, elated by their offer, suggested that they set up a public lecture in a dark corner of their native county. He later recalled how well the charitable concerns of this first Worcestershire feast tied in with his concurrent actions to establish a clerical association in the county. Almost thirty years later, in 1682, Roger L'Estrange noted the same phenomenon of annual county feasts in London. Like Baxter, L'Estrange defended what he termed the “innocent county feasts,” and hisObservatoradvertised both tickets and published sermons for more than a dozen county or city feasts during its brief run between 1681 and 1687. Such common cause between Baxter and L'Estrange is remarkable. Moreover, the “innocent” county feasts, which flourished for fifty years from the late 1650s, were often controversial and were the setting for feast sermons which often heaped vitriol on “parties,” whether religious or political. This article examines the rise of the county feasts in the 1650s and their peak in the 1680s in order to assess their significance in the development of late Stuart society, culture, and politics.The county feast was in fact an urban phenomenon: natives of a county met annually, usually in London, for a sermon, dinner, and a subscription to a charity. The phenomenon has long been noted, though rarely analyzed.


2018 ◽  
Vol 15 (2) ◽  
pp. 80-92
Author(s):  
Akmal Hakim ◽  
Zainal Abidin Mohamed

This case is about a few small business enterprises in the construction industry that were operating in one of the district in Selangor. In their regular acquaintance in the district, the five owners decided to jointly set up a holding company, with 5 subsidiaries, and the fifth one being the new brick manufacturing plant (churning out interlocking bricks). Most of them had not being formally trained in business. They faced some difficulties in the management of a holding company where they had to be more aware of what is required of being Board members and managing the subsidiaries. They are now jointly responsible not only for their own subsidiary but also the others under the Holding structure. With the new interlocking brick manufacturing factory, life had become a bit more challenging and this case reflects the difficulty of working as board members and managing the 5 subsidiaries. While they had climbed into a higher level of technology usage (IBS as compared to the normal brick and mortar technology), their management was still individualistic in nature and this case will demonstrate these common weaknesses through the financial problems that they had to endure.


Author(s):  
Usharani N. ◽  
Swetha D.

Background: Vaginal discharge in the reproductive age group is the most common complaint encountered everyday both by gynaecologists and general practitioners. The prevalence of vaginal discharge in India is estimated to be 30%. Bacterial vaginosis is the most common cause, followed by Candidiasis and Trichomonasis. Aims and objectives of the study were to correlate clinical and microscopic methods for diagnosing abnormal vaginal discharge and to find out the most common cause of abnormal vaginal discharge in our set up.Methods: The study was carried out in Gynaecological OPD of VIMS, Ballari. After thorough history and gynecological examination, three samples were collected from the posterior fornix of vagina using sterile cotton swabs. The first swab was used to detect trichomonas vaginalis using wet mount microscopy. The second swab was used to determine amine/fishy odour (Whiff test). The third swab was used for gram staining to diagnose Bacterial vaginosis and Candida. The Gram-stained slides was evaluated using Nugent’s scoring system for detection of BV.Results: Bacterial vaginosis constitutes the most common cause of vaginal discharge, followed by Candidiasis and then Trichomoniasis in our set up. The sensitivity of clinical diagnosis is 71.93%, 88.9%, and 33.3% and specificity are 54.65%, 92.15% and 99.49% for Bacterial vaginosis, Candidiasis, and Trichomoniasis respectively.Conclusions: The most ideal approach is the microbiological approach for the etiological diagnosis of symptomatic vaginal discharge. The most common cause of abnormal vaginal discharge is Bacterial vaginosis followed by Candidiasis and Trichomoniasis.


2016 ◽  
Vol 12 (3) ◽  
pp. 197-203
Author(s):  
P Upadhyaya ◽  
C S Agarwal ◽  
A K Karak ◽  
S Karki ◽  
A Pradhan ◽  
...  

Background: Appendicitis is the most common cause of acute abdominal pain requiring surgical intervention. Objective: To determine the relative prevalence of histologically proven acute appendicitis in surgically respected specimens with clinical diagnosis of acute appendicitis and also to find out the rate of occurrence of characinoid tumour as an incidental histologic finding.Methods: It is a retrospective study involving all gross specimens received in the department of pathology over a period of twenty months (1.1.2006 to 31.8.2007). Histologic data on 515 appendicectomy samples (clinically diagnosed as appendicitis) of the total 7295 specimens received over a period of twenty months were retrieved from the archives of department of pathology, with exclusion of appendectomy incidental to another surgical procedure.Results: Appendectomy specimens constituted 7.0% (n=515; M:F 1.1:1) of all surgical pathologic specimens (n=7295) at B.P.K.I.H.S. The breakups of histologic diagnoses are: acute appendicitis with or without periappendicitis and gangrenous change (93.6%, n=482), “receding appendicitis” (5.4%, n=28), and normal histology (1.0%, n= 5). Carcinoid tumours were detected incidentally in three cases (0.58%) out of all appendectomy specimens.Conclusion: Analysis of data revealed a prevalence of 6.99% of histologically proven acute appendicitis in this tertiary health care set up. The rate of occurrence of carcinoid tumour was 0.58%.Health Renaissance 2014;12(3): 197-203


1990 ◽  
Vol 32 ◽  
pp. 117-144
Author(s):  
A. Kerr ◽  
I. Rogers

Traditionally the interest of actuaries and many other life assurance specialists in the ‘corporate structure’ of life offices has largely been limited to questions surrounding the distinctions between mutual and proprietary companies. More recently, attention has also been paid to composite insurance companies—principally to protect the interests of the long term business policyholders.Developments over the past ten years or so have led many life offices to reappraise their corporate structure. A number of companies have decided to set up a (non-insurance) group holding company, the principal subsidiary of which would be the established life assurance company. This paper will consider some of the pressures which have resulted in these reorganizations, in particular:(a) the impact of Section 16 of the Insurance Companies Act 1982 which restricts insurance companies to only conducting activities in connection with insurance;(b) the various provisions in the Insurance Companies Regulations 1981 which limit the admissibility of particular assets and specify minimum accounting standards which must be adopted when writing down certain fixed assets;(c) the additional flexibility with regard to marketing and the financing of marketing costs which a revised structure will allow;(d) the purchase of companies for sums substantially in excess of their net asset value which may give rise to difficulties in accounting for the ‘goodwill element’ in the purchase price;(e) the potential tax advantages (and, in some cases, disadvantages) which may result from the creation of a non-insurance holding company.


1988 ◽  
Vol 13 (4) ◽  
pp. 59-68

(In their article “Can a Holding Company be an Effectiye Buffer for Government Enterprise?” (Vikalpa, July-September 1988), K R S Murthy and N C B Nath argued that the holding companies for public enterprises set up by the Government of India, so far, had been unable to buffer the operating units from governmental planning and control. Agreeing with their thesis, Ramaswamy R Iyer says that no , holding company in the real sense of the term has been tried in the Indian public sector. S V S Raghavan points out that the Arjun Sengupta Commi'ttee had envisaged a new concept of the holding company that involved new norms for government planning and control. He elaborates on that concept and provides the rationale for the recommendation-Ed.)


2012 ◽  
Vol 220-223 ◽  
pp. 224-228
Author(s):  
Wen Ying Chen

Basic principle and inference algorithm of Bayesian network (BN) were emphasized. As to the Fault Tree with basic events of common cause failure, accident probability cannot be computed correctly. An open press blunt hand accident risk assessment BN model was set up, in addition, the BN nodes of common cause failure were illustrated and the accident probability of occurrence was obtained. The discussions about computed results indicate that regarding to system with unit events of common cause failure or interdependent events, result of accident probability computed from a BN model is higher than that computed from the Fault Tree/Event Tree model.


Author(s):  
Monica Arora ◽  
Suniti Verma ◽  
Ranjana Desai ◽  
Ram Narain Sehra

Background: The objective of the study was to study the incidence of jaundice, biochemical alterations, Fetomaternal outcome and various liver pathologies of pregnant patients with jaundice.Methods: This was a prospective observational study conducted in Dr S N Medical College Jodhpur, Rajasthan, India from June 2014 to February 2016. Total fifty pregnant patients with clinical jaundice and prodromal symptoms of hepatitis were included in study.Results: Out of 40,398 deliveries in our hospital, 50 cases of jaundice were identified giving an incidence of 1 in 808 (0.12%). Most common cause of jaundice in pregnancy in our set up was viral hepatitis i.e. 13 cases (26%) were HEV+ and 1 case (2%) came out to be HAV+. Serum LDH levels were raised in 36% of patients. Maximum no. of patients had their serum AST/ALT levels in the range of 100-1000 IU/ml (54%). Out of 52 births (2 twins) 34 were live births (65.38%) and rest were either SB or IUFDs. Most common causes of mortality in patients were Septicemia, MODS, DIC (25%) followed by HELLP syndrome and HEV+ viral hepatitis equally (16.67%). Maximum no. of patients with jaundice suffered from postpartum haemorrage and septicemia (60%).Conclusions: Most common cause of jaundice in pregnancy in our study was viral hepatitis. Public awareness about the various routs of transmission of different types of infective hepatitis, improving sanitary conditions and habits, health education of preventive measures can help in reducing the burden of jaundice in pregnancy.


Author(s):  
T. G. Naymik

Three techniques were incorporated for drying clay-rich specimens: air-drying, freeze-drying and critical point drying. In air-drying, the specimens were set out for several days to dry or were placed in an oven (80°F) for several hours. The freeze-dried specimens were frozen by immersion in liquid nitrogen or in isopentane at near liquid nitrogen temperature and then were immediately placed in the freeze-dry vacuum chamber. The critical point specimens were molded in agar immediately after sampling. When the agar had set up the dehydration series, water-alcohol-amyl acetate-CO2 was carried out. The objectives were to compare the fabric plasmas (clays and precipitates), fabricskeletons (quartz grains) and the relationship between them for each drying technique. The three drying methods are not only applicable to the study of treated soils, but can be incorporated into all SEM clay soil studies.


Author(s):  
T. Gulik-Krzywicki ◽  
M.J. Costello

Freeze-etching electron microscopy is currently one of the best methods for studying molecular organization of biological materials. Its application, however, is still limited by our imprecise knowledge about the perturbations of the original organization which may occur during quenching and fracturing of the samples and during the replication of fractured surfaces. Although it is well known that the preservation of the molecular organization of biological materials is critically dependent on the rate of freezing of the samples, little information is presently available concerning the nature and the extent of freezing-rate dependent perturbations of the original organizations. In order to obtain this information, we have developed a method based on the comparison of x-ray diffraction patterns of samples before and after freezing, prior to fracturing and replication.Our experimental set-up is shown in Fig. 1. The sample to be quenched is placed on its holder which is then mounted on a small metal holder (O) fixed on a glass capillary (p), whose position is controlled by a micromanipulator.


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