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  2. 2. Restructuring under the first agreement GPA GPA owns 100% GPA transfers land to be of GPH satisfied by issue of shares in GPH GPH Restructuring under the second agreement GPA Bumiputra company GPA transfers its land to GPH, to be satisfied by GPA now shares and cash in GPH Bumiputra owns only company now owns70% of GPH 30% of GPH GPHSection 15A exemption will apply only if GPA holds 90% or more of the shares of GPH. If 30% of theshares of GPH are to be divested to a Bumiputra company, then GPA will only hold 70%. GPA thereforewill not qualify for exemption, by the sheer fact of complying with the Foreign Investment Committee’srequirement.