Assignment Task:
Raze Ltd
Raze Ltd (Raze) is incorporated and tax resident in Country A. Raze provides various support services to companies within Raze group. These services include human resource, accounting, legal and IT support services which are performed by the employees located in Raze's office in Country A.
Co B
Company B (Co B) is incorporated and tax resident in Country B. Co B manufactures ergonomic computer chairs and it has its sole manufacturing plant in Country B. Co B sells all its ergonomic computer chairs to Company E, the distributor company within the group.
Co C
Company C (Co C) is incorporated and tax resident in Singapore. Co C 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 C will be on lent to Co B and Co E for use in their business operations in exchange for interest.
Co D
Company D (Co D) is incorporated and tax resident in Country D. Co D employs a team of research and development specialists in its office in Country D to develop the patent used for the manufacture of ergonomic computer chairs. Co D is the legal and economic owner of the patent. Co D licenses the patent to Co B for an annual royalty fee.
How should I examine and analyse company D to advise them on potential tax implications?