- This ruling determines the income tax consequences resulting from cash contributions to be made by the applicant to a special purpose vehicle (separate property company) established to provide housing for the employees of the joint venture and the group of companies of which the Applicant forms part. The separate property company (SPV) will obtain funding and provide housing to mine workers, in order for the company to apply for a renewal of its mining rights.
- Upon completion of the housing projects undertaken by separate property company, all surplus cash and profits shall be applied to programmes that have as its object the improvement of the social conditions of the communities in or around the area in which the Applicant carries on its business.
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