Case Study 2 – Singapore – Mauritius Mozambique Structure (Continued…) •  US$ 10,000,000 is paid as interests by a Mozambique Company to its holding located in Singapore •  Percentage Tax withheld in Mozambique is 20%, i.e. US$ 2,000,000 APPLE BY Case Study 2 Singapore Mauritius - Mozambique Structure Proposed Structuref Singapore Mozambique Co pays Interest to Mauritian Co WT 8% under DTT Holdin ?-LMauritius Caj? 1100 ozambique Mauritian Co pays interest to Singaporean Holding Exempt under Case Study 2 – Singapore – Mauritius Mozambique Structure – (Continued…) •  Withholding Tax savings of 12% or US$ 1,200,000 •  Assuming the cost of running the company amounts to US$ 30,000, the net savings shall amount to US$ 1,170,000.