Service Procurement Centre OFFSHORE 6 Mauritius expertise acquired director Holdco RSA senior management employees manufacture widgets expertise AFRICA Subco’s business systems know-how financials 1 2 3 4 5 widgets CFO Africa Individual RESPONSIBLE director Individual AFRICA CFO Resident Non-Residents PRINCIPLES OF SOURCE POEM acquisition raw materials services know-how how to manufacture, business systems, financial issues PAYMENT Holdco RSA 1 1 1 5 6 Payments 2 CFO AFRICA