Australian Agritech Adds DMCC Sub for GCC Sales Expansion

Brisbane HQ Pty Ltd, AUD 28M revenue, 62 employees, ASX watch-listed. GCC revenue growth AUD 2.4M → AUD 9.1M (FY22-24). Constraints: preserve ASX listing path, FIRB/ATO compliance, minimise GCC-revenue effective tax. Hub-and-spoke: Pty Ltd retains IP/R&D/AU+ASEAN customers; DMCC sub as Limited Risk Distributor at 7% TNMM cost-plus for GCC. Subdivision 855-A preserved (no deemed disposal). 6-week DMCC setup under Management Consultancy + Software Designing activities. Three Dubai-based hires. AUD-AED TP memorandum (32 pages) satisfying ATO Subdivision 815-E + UAE FTA MD 97/2023. Effective GCC tax reduced ~60% vs pre-existing all-AU booking. Customer onboarding 11 weeks → 4 weeks.

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