Inside Aura Digital's Three-Tier Holding Structure: 24.95% Stake in TRUE Unlocks 100% Dividend Tax Exemption

Corporate ActionManagement
โดย InfoQuest·TH·Read original
Summary · why it matters

The shareholding structure of the Aura Digital Technology group, which acquired a 24.95% stake in True Corporation Public Company Limited, has been scrutinised in depth by capital-market analysts. Data from the Department of Business Development reflects a blueprint of a three-tier nested holding structure comprising Aura Digital, Aura Holding, and Ubonmas Digital, which opens options to accommodate multinational partners and manage dividend tax seamlessly. The stake was capped at 24.95%, a technical figure designed to avoid the 25% trigger point that would require a full tender offer for all securities, alongside a put/call option agreement covering a further 5.35%. Although holding 24.95% of TRUE entitles Aura Digital to only a 50% dividend tax exemption under Section 65 bis (10) of the Revenue Code, the design whereby Aura Holding and Ubonmas Digital hold shares in a nested structure at the upper tiers at a ratio as high as 99.99% is the key that unlocks the full 100% dividend tax exemption, allowing cash flow to pass up to the top of the pyramid without double taxation. Governance analysts are watching the appearance of Supachai Chearavanont's name as a person with controlling authority holding 99.99% of Ubonmas Digital Company Limited, while he also sits on the executive board of a large listed company, CPAXT. This raises a governance challenge should related-party transactions arise in the future, and leads to a proposal that the Securities and Exchange Commission upgrade disclosure of ultimate beneficial owners to maintain governance standards.

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Off-coverage companies 3

อไรซ์ ดิจิทัล เทคโนโลยีPrivate± Mixed
Capitalrelevance

Aura Digital's three-tier holding structure and 24.95% TRUE stake are the subject of the article, unlocking a 100% dividend tax exemption.

Arize HoldingPrivate± Mixed
Capitalrelevance

Aura Holding is a tier in the nested holding structure that enables the full dividend tax exemption on the TRUE stake.

อุบลมาศ ดิจิทัลPrivate± Mixed
Regulationrelevance

Ubonmas Digital sits in the nested structure and Supachai Chearavanont's 99.99% controlling stake in it draws governance scrutiny.

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