In December 2018, the Income Tax Act was amended to extend thin capitalization rules to non-mining sectors. The Act was further amended in August 2019 and the Minister of Finance has since issued a commencement order to exclude Variable Rate Loan Stock Companies (VRLSC) from the rules as they are financed mostly through debt.
The Income Tax Act defines a VRLSC as "a company with limited liability in Botswana in terms of the Companies Act, the objects of which in terms of its Memorandum of Association are restricted to investment in immovable property and the development, refurbishment and maintenance thereof, and which, in terms of its Articles of Association, issues shares and debentures which together comprise linked units".
Linked units refer to a situation where shares and debentures are issued as a package and may not be disposed of independently. Each unit will comprise of a share and a debenture unit. A P100 unit may comprise of a P10 share and P90 debenture. The result of this mechanism is that the company will be highly geared and therefore has a huge liability of interest. The thin capitalization rules were going to badly affect their returns hence there was a need to exempt them.
This model is used by property development companies such as Prime Time, NAP and FAR Property. VRLSC have their expense as predominantly interest as they are highly leveraged, applying thin capitalization rules would have badly affected their business operations. In addition, the amendment exempt micro, small or medium enterprises, which are companies that do not belong to a group. Companies that are regarded as associated companies are those that are owned by other companies with more than 20% shareholding.
Companies that have individual shareholders will not be regarded as group companies for purposes of this section. Capital intensive industries companies that have individual shareholding will therefore have a competitive advantage over those with predominantly company shareholding. This applies to both resident and non-resident taxpayers (individuals and companies).
The limitation of interest deductible rules are among efforts by government to close gaps in the tax system and ensure the tax base is not eroded. This is extensively covered by Action 4 of the Organization of Economic Cooperation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan. Though ideally a good development from government perspective, it is still unclear on how 3rd parties erode tax base as those interest payments are taxed on financial institutions’ hands and are not part of group companies’ tax planning initiatives.
Impatience lives within all of us; in some even more so than in others. When impatient some people will get fidgety, mumble and curse under their breath or even losing their tempers and being rude to others, whilst on the other hand others will be cool, calm and collected. Impatience comes in different packages and can stem from many sources.
We go through our daily lives with usual things like queuing at the bank, post office, government offices and other places of poor customer service that irk and irritate most of us. Unacceptable but somewhat understandable because of the insensitivity or inefficiency of others the rest have to suffer.
Taking it up to another level, specifically onto a ‘religious’ one, we come across many who show impatience with their lives because of their high expectations leading them to believe that their prayers are not being answered. For them Allah has a message: “Be sure we shall test you with something of fear and hunger, some loss in goods or lives or the fruits (of your toil), but give glad tidings to those who patiently persevere, who say, when afflicted with calamity: ‘To God We belong, and to Him is our return’. They are those on whom (descend) blessings from their Lord” (2:155-157)
Sometimes we strongly pray for something and we get despaired when our prayers are ‘not answered’. But remember: ‘Allah is with those who patiently persevere’. (Quran 8:46). We have to realise and accept that the Lord is in complete control of everything – we cannot always get what we want because the Lord knows best what is good for us, accept the will of God. ‘But it may happen that you dislike a thing which is good for you, and it may happen that you love a thing which is bad for you. And God knows and you do not know!’ (Quran 2:216)
A believer should rather ask Allah to bless him, make it easy for him and to grant him what is good in this world and in the hereafter. Be positive and look at the other blessings that you have instead. “Pray for help from God, and (wait) in patience and constancy: for the earth is God’s, to give as a heritage to such of His servants as He pleases; and the end is (best) for the righteous.” (Quran 7:128)
On the other hand, think about it, when things go wrong we go into a tailspin, start blaming ourselves, others and at the worst we begin to question why the Lord has not favoured us, yet we forget the countless other daily bounties that the Lord has blessed us with. ‘When trouble touches a man, he cries unto Us, in all postures, lying down on his side, or sitting, or standing. But when We have solved his trouble, he passes on his way as if he never had cried to Us….’ (Quran 10:12)
When the stresses of life hit us and we are faced with challenges, it is only then that some of us turn to our Lord in prayer. Unfortunately, it is human nature to forget our duty and allegiance to our Creator when things run smoothly in our lives. This is true because when the going is good we put it down to our own efforts. Nothing wrong with that but we need to realise that all that happens is through the Will of God.
‘…… when We bestow a favour upon him as from Ourselves, he says, “This has been given to me because of a certain knowledge (I have)!” Nay, but this is but a trial, but most of them understand not! (Quran 39:49)
We have become so obsessed with this material world that we have separated and compartmentalized our lives away from our faith because everything now revolves around moving up the economic ladder of life regardless of the cost to our souls.
Unfortunately many of us are impatient of the favours of our Lord we want things to happen now. We forget that the Almighty has a plan for each and every one of us, the good times, the bad times; the happy times, the sad times; the difficult times and the time of ease; and so it goes. From my school days, in physics class, I recall the saying that ‘for every action there is an equal and opposite reaction’ – I suppose so it is with life.
The question is; if we are so impatient about the ‘good’ in our life what about the bad? The Almighty asks us: ‘Do they then ask for Our penalty to be hastened on?’….yet there comes to them at length the punishment which they were promised’ (Quran 26: 204 – 206). Therefore we should balance our desires and pray for guidance, assistance and at the same time pray for peace of mind.
Impatience manifests itself into many people turning to those self-proclaimed ‘prophets’ – enough said. They promise you great wealth, worldly gains, winning of tenders and all those dazzling promises they make. Sadly many people are convinced that the ‘gospel of prosperity’ that these so-called prophets preach is the answer.
Remember you cannot buy God’s favour with money, so what are you paying that prophet for – the only answer is, for his own ‘profit’? I remind them to read the Bible: “Thy money perishes with thee because thou hast thought that the gift of God may be purchased with money”. (Acts 8; 20)
Think of those daily blessings that we take for granted, and which we should be grateful for to our Lord, rather start counting your blessings before counting your ‘shortages in life’;
Before you say an unkind word – Think of someone who can’t speak. Before you complain about the taste of your food – Think of someone who has nothing to eat. Before you complain about your partner – Think of someone who’s crying out to GOD for a companion. Before you complain about life – Think of someone who died too young. Before you complain about your children – Think of someone who desires children but they’re barren. Before you complain about the small house you live in – Think of the people who don’t have homes. Before complaining about the distance you to drive to work – Think of someone who walks the same distance but on foot. And when you complain about your job – Think of the unemployed who wish they had any job. Before you think of pointing the finger or condemning others – Remember that not one of us is without sin and we all answer to one MAKER. Also when you are pointing at others – one finger is ‘at’ them – but at least three of your fingers are pointing ‘back’ at you. When depressing thoughts seem to get you down – Put a smile on your face and thank GOD you’re alive and still around.
As the Quran repeatedly asks: ‘…..then which of the favours of your Lord will you deny’ (Surah 55)
Don’t be impatient, trust in your Lord, that trust will never be misplaced. ‘If Allah is your helper none can overcome you, and if He withdraws His help from you, who is there who can help you? In Allah let believers put their trust’ (Qur’an 3:160) Let us think of our daily Blessings.
Princess Diana was at once a child of destiny and a victim of fate
It is no secret, General Atiku, that the British monarch constitutes one of the most moneyed families on this scandalously uneven planet of the perennial haves on the one hand and the goddamn havenots (such as you and me General) on the other hand.
In terms of residences alone, the House of Windsor lays claim to some 19 homes, some official, such as Buckingham Place and Windsor Castle, for instance, and the greater majority privately owned. Arguably the most eminent of its private residences is Sandringham House at Sandringham Estate in Norfolk, England.
It is at this sprawling, 8,100-hectare estate the Queen spends two months each winter, at once commemorates her father King George VI’s death and her own accession to the throne, and more often than not celebrates Christmas. King George VI and his father King George V both drew their last breath here.
A 19th century Prince of Wales, Albert Edward (who would later become King Edward VII), acquired Sandringham in 1862 and it has remained royal property ever since. On the death of King George VI in February 1952, the property passed to his successor Queen Elizabeth II, the incumbent monarch, who assigned her husband Prince Phillip its management and upkeep. The estate also houses a parish, St. Mary Magdalene Church, which the outwardly religious Queen attends every Sunday.
Albert, General, had several additional properties built on the estate the year after he acquired it, one of which was the ten-bedroomed Park House. The house was built to accommodate the overflow of guests at Sandringham House. In the 1930s, King George V leased Park House to Maurice Roche, an Irishman and a bosom friend to his second son, who at the time was Duke of York but would in future be King George VI.
Roche was the 4th Baron Fermoy, a title in the Peerage of Ireland created by Queen Victoria way back in 1856. He and his wife Ruth had three children born at Park House, the second-born of whom was Frances Ruth Roche (futuristically Frances Shand Kydd), born in January 1936.
In 1956, Frances married John Spencer, a fellow noble, and following an “uneasy spell” at Althorp, the Spencer family estate of 500 years, the couple took up residence at Park House, which would be their home for the next 19 years. On July 1, 1961, Frances, then aged 25, and John, then aged 37, welcomed into the world their thirdborn child and youngest daughter, Diana Frances Spencer.
She would, on a positive note, become Her Royal Highness Princess Diana of Wales and the most famous and popular member of the Royal family. On the flip side of the coin, she would, as you well know General, become the most tragic member of the Royal family.
GIRL CHILD WHO SHOULD HAVE BEEN A BOY
If there was one thought that constantly nagged at Diana as a youngster, General, it was the “guilt” of having been born anyway. Her parents first had two daughters in succession, namely Elizabeth Sarah, born in 1955, and Cynthia Jane, born in 1957. Johnnie was displeasured, if not downright incensed, that his wife seemed incapable of producing a male child – a heir – who he desperately needed as an aristocrat.
He even took the trouble of having his wife see a series of doctors in a bid to establish whatever deficiency she possessed in her genetic make-up and whether it was possible to correct it. At the time, General, it was not known that it is the man who determines a child’s sex and not the woman.
John’s prayers, if we can call them that General, were as much answered as they were unanswered. The longed-for male heir was born on January 12, 1960. Named John after his father, he was, as per the official version of things, practically stillborn, being so piteously deformed and gravely ill that he was dead in a matter of only ten hours, a development of which Earl Spencer would in future remark thus, albeit with tongue-in-cheek: “It was a dreadful time for my parents and probably the root of their divorce because I don’t think they ever got over it.”
Again as per the official version, General, John was gutted and hurriedly got into stride, this time around utterly positive that having had two daughters in succession, it would be two sons in succession. But nature, General, is seldom that predictable or orderly.
The next child was in fact a daughter, the now iconic Diana, for the third time around. Although John is recorded as having marvelled at what a “perfect physical specimen” her newly-born daughter was, he was forlorn beneath the façade, as a result of which Diana, who as a child did sense a lingering frustration on the part of her father on her account, would openly intuit that she was an unwelcome child, a “nuisance to have around”, thanks to her “failure” to be born a boy. From a very age thus, General, Diana had concluded that she was not well-fated and presciently so!
Although the heir, Charles Spencer (the future Earl Spencer) finally arrived on May 20, 1964, Diana perceived very little if any change in the way she was contemplated by her parents. In fact, both she and Charles could not desist from wondering whether had John lived, they would have been born at all. Seemingly, they came to be simply because their father was desperate for a heir and not necessarily that he wanted two more children. With the birth of Charles, General, John called it a day as far as the process of procreation was concerned.
GODDESS OF THE HUNT
Why was Diana so named, General? Throughout her life, it was taken as an article of faith that her name derived from Lady Diana Spencer, a member of the Spencer clan who lived between 1710 and 1735, dying at a pitifully tender age of only 25. Certainly, the two namesakes turned out to have precious much in common as we shall unpack at a later stage, as if the latter-day Diana’s life was deliberately manoeuvred to more or less sync with the ancestral Diana.
It emerged, however, General, that the connection to an ancestor was actually secondary, or maybe incidental. The primary inspiration of the name was at long last disclosed by Earl Spencer on September 7, 1997, the day of Princess Diana’s burial. Delivering the elegantly crafted eulogy, Earl Spencer had this to say in relation to her naming: “It is a point to remember that of all the ironies about Diana, perhaps the greatest was this – a girl given the name of the ancient goddess of hunting was, in the end, the most hunted person of the modern age.”
It is significant, if not curious, General, that of John’s three daughters, only Diana was given the name of a goddess. Clearly, there must have been a special reason for this as aristocrats do not confer names casually: every name carries a metaphorical, symbolic, or intentional message. Typically, it honours an iconic personage or spirit or somebody lesser but who evokes memories anyway.
Elizabeth Sarah, for instance, was in all probability named after the Queen’s mother, whose decades-long inner circle included Diana’s paternal and maternal grandmothers, and an ancestor going by the name Sarah Jennings (1760-1744). Charles Spencer was named after the family’s greatest forbearer, King Charles 1 of England, Scotland, and Ireland from 1625-1649. The ill-fated John was of course named after his father, who in turn was likely named after the 5th Earl Spencer, John Poyntz Spencer (1835-1910).
On occasion in occultic families, as the Spencer family latterly have been, a name, General, connotes a bad futuristic omen associated with its bearer and that was precisely the case with Diana.
THE FIRST DIANA
In its ancient rendering, the name Diana meant “The Heavenly One”, or goddess being a feminine style. The first Diana, General, was Inanna, an Anunnaki goddess whose Akkadian name was Ishtar – Esther in English. As you well know General, the Anunnaki are the Old Testament gods, Aliens from the planet Nibiru, the Solar System’s little-known planet which is seen only once in 3600 years, and who came to Earth 432,000 years ago as we comprehensively set down in the Earth Chronicles series.
The name Inanna is Sumerian, the Sumerians being the best-known civilisation of old who thrived around modern-day Iraq (called Sumer in ancient times) about 6000 years ago and who were indirectly governed by the Anunnaki. It was abbreviated from Nin-An-Ak, meaning “Lady of Heaven and Earth” or “Lady of the God of Heaven and Earth”.
She was so-called, General, not because she had particularly special godly qualities but owing to the fact that she was the earthly mistress of Anu, “Our Father Who Art In Heaven”, the King of the planet Nibiru, which humans of the day perceived as Heaven.
Anu was the father of Enlil, the principal Jehovah of the Bible. Enlil in turn had a second-born son called Nannar-Sin, the first Anunnaki to be born on Earth and who eventually became the Allah of Islam. It was Sin who fathered Inanna. Thus Inanna was Anu’s great-granddaughter but every time he visited Earth, Anu was sexually entertained by the stunningly beautiful Inanna, an act which in Anunnaki culture was not frowned upon.
Inanna was amongst other appellations known as the Goddess of Hunting (because of her penchant for, and skill in, waging war) and the Goddess of Love (in the sense of licentious love-making and not conventional moral love). Her other names in different parts of the world and across the ages were Irnin; Anunitu (Beloved of Anu); Aphrodite; Ashtoreth; Astarte; and Artemis, to mention only a few.
Although her celestial counterpart was the planet Venus, she was also loosely associated with the constellation Virgo as well as the moon. Once upon a time, when she was a virgin, Virgo was dedicated to her by her grandfather Jehovah-Enlil, who was Earth’s Chief Executive until circa 2024 BC. With regard to the moon, it primarily had to do with her twin brother Utu-Shamash, whose celestial counterpart was the sun: as such, Inanna’s inevitably had to be the moon. That, however, was only in a putative sense in that the operative moon god of the day was her father Sin.
Since moonlight effectively turns darkness into relative daylight, Inanna has in legends been referred to as Diana Lucifera, the latter term meaning “light-bringer”. Inanna’s association with the moon, General, partly explains why she was called the “Heavenly One” since the moon is a heavenly body, that is, a firmament-based body. It also explains why she was also known as Luna, which is Latin for moon.
A STEERED LIFE FOR GOOD OR ILL
Now, children of royals, aristocrats and other such members of high society, General, are invariably named before they are born. True, when a Prince William or Prince George comes along, the word that is put out into the public domain is that several names have been bandied about and the preferred one will “soon be announced”. That, General, is utter hogwash.
No prince, princess, or any other member of the nobility for that matter, is named at or sometime after their birth. Two names, a feminine and a masculine one, are already finalised whilst the child is in the womb, so that the name the child eventually goes by will depend on no other factor beside its gender.
Princess Diana, General, was named a full week after her birth, as if consultations of some sort with certain overarching figures had to be concluded first and foremost. Apparently, the broader outlines of her future first had to be secretly mapped out and charted in the manner of a child of destiny, though in her case she was as much a child of destiny as she was a doomed child. In her childhood reminiscences, Diana does hint at having been tipped to the effect that she was a special child and therefore had to scrupulously preserve herself.
“I always felt very different from somebody else, very detached,” she told her biographer Andrew Morton as per his 1992 book Diana Her True Story – In Her Own Words. “I knew I was going somewhere different but had no idea where. I said to my father when I was 13, ‘I know I am going to marry someone in the public eye’.” That, General, speaks volumes on the deliberately designed grooming she was subjected to in the formative years of her pilgrimage in life.
Since it was repeatedly drummed in her highly impressionable mind that there was something big in store for her along the way, Diana, General, remained chaste throughout her upbringing, if not an outright virgin to in all probability conform to the profile of the goddess Diana/Inanna before she exploded into a lecherous, loose-mannered nymphomaniac in her adult life as we underscored in the Earth Chronicles series. “By the time I got to the top of the school,” Diana said to Morton, “all my friends had boyfriends but not me because I knew somehow that I had to keep myself very tidy for whatever was coming my way.”
A DISPARAGED BIRTH?
Unusual for an aristocrat, General, Diana was born not in the rather apt precincts of a high-end hospital but within the banality of Park House itself. Whether hired midwives were on hand to help usher her into the world or it was only her dad, mum and closer womenfolk relations who did we can only speculate.
If for one reason or the other her parents were desirous that she be delivered at home, what secret rites did they perform as her mother’s waters broke, General? What incantations, if at all, did John utter over her? Was her birth an occultic one with all the attendant paraphernalia as opposed to a conventional one?
That Diana’s arrival was not a particularly cherished event, General, is evidenced by the fact that she was christened within the Sandringham Estate, at St. Mary Magdalene Church, with only well-to-do commoners in attendance, whereas the more prized child, her younger brother Charles, was christened at Westminster Abbey, in the presence of the Queen, who was designated as his principal godmother.
Anyhow, it was just as well, General, that it was in the hallowed environs of St. Mary Magdalene Church that Diana was committed to the “The Lord” as she was in a manner of speaking the Mary Magdalene of our day.
Allah Almighty reminds us: ‘On no soul does Allah place a burden greater than it can bear’ (Qur’an 2:286). Also: “Be patient. Surely, Allah is with those who are the patient.” [Qur’an 8: 46].
Without fail, whether we like it or not there are times in our lives when many things seem to go wrong and as mere humans we go into a panic syndrome and are left wondering; why me? Why now? What have I done to deserve this? We are all tested with adversity, hard times and pain, but these tribulations are the Almighty’s way of transforming us and help us develop spiritually.
As mere humans we all have different reactions when something good or bad happens to us, and usually our reactions depend on the strength of our religious belief and of our righteous deeds and actions.
One person may receive blessings and goodness with gratitude and accepts the bad challenges and patches in his life with perseverance and endurance. This positive attitude brings him peace of mind and happiness, causing his grief, anxiety and misery to ease. Thus, this positivity brings a balance and contentment in his life.
On the other hand another person receives blessings and goodness with arrogance and transgression; his manners degenerate and become evil; he receives this goodness and utilizes it in an unthinking and uncaring manner; it does not give him any peace of mind as his mind is always distressed, nervous and restless.
Thus when faced with loss and difficulty, due to his arrogant nature, he begins to ask why me? What have I done to deserve this and he may even damn and curse others and thinks that they are plotting his downfall.
But every now and then we should stop to ponder over the blessings both apparent and hidden from The Almighty upon us, it is only then that we will realise that our Lord has granted us abundant blessings and protected us from a number of evils; this will certainly ease our grief and anxiety and bring about a measure of happiness and contentment.
Prophet Muhammad (PBUH) said: “Look to those who are lower than you (those who possess less than you) and do not look to those higher than you; this will make you appreciate the bounties of Allah upon you.”
Whether we are believers or disbelievers, virtuous or sinful, most of us are to a certain degree able to adapt and condition ourselves to face adversity and remain calm during these moments of challenge, uncertainty and upheaval.
When people receive affliction with fear, discontent, sorrow and despair; their life becomes miserable, they panic and become short tempered. Such people are unable to exercise patience remain restless, stressed and cannot find contentment that could make life easier for them.
On the other hand, due to a believer’s strong faith and reliance on Allah, it makes him persevere and he emerges stronger than others in difficult situations as this reduces his fear and anxiety and that ultimately makes matters easier for him. If he is afflicted with sickness, poverty or any other affliction, he is tranquil and content and has no desire for anything which has not been decreed for him.
‘If Allah touches you with affliction, none can remove it but He; if He touches you with happiness, He has power over all things’ (Qur’an 6: 17).Therefore the believer prays to his Lord: ‘Our Lord, condemn us not if we forget or fall into error…lay not on us a burden greater than which we have the strength to bear’ (Qur’an 2:286)
However, the one who is weak in faith will be just the opposite; he becomes anxious, nervous, confused and full of fear. The anxiety and paranoia will team up against him because this person does not have the faith that could enable him to persevere during tough times, he is less likely to handle the pressures and will be left in a somewhat troubled and depressed state of mind.
It is natural that as humans we are always fearful of losing the things that we have acquired; we desire and cherish them and we are anxious to acquire more, because many of us will never reach a point where we are satisfied with the material things in life.
When certain frightening, disturbing or unsettling events occur, like emergencies or accidents we find that a person with sound faith is calm, steadfast, and able to cope with the situation and handle the hardship he is going through; such a person has conditioned himself to face afflictions and this makes his heart stronger and more steadfast, which gives him a level of tranquillity.
This shows the difference between a person who has strong belief and acts accordingly, and another who is not at this level of faith. Due to the strong belief of the true believer he is content with whatever Allah Almighty has decreed,
This life is full of ups and downs and uncertainties, but the only certain thing is that from the moment we are born we will be tested with life’s challenges throughout our entire lives, up to and to the final certainty, death. ‘Be sure We shall test you with something of fear and hunger, some loss in goods or lives, or the fruits of your toil, but give glad tidings to those who patiently persevere’ (Qur’an2:155).
The Prophet Muhammad (PBUH) said: “How wonderful is the matter of the believer! All of his matters are good and this is the case for nobody except a believer. If he is blessed with prosperity he thanks (Allah Almighty) and that is good for him; and if he is afflicted with adversity he is patient and perseveres and that is also good for him.”
During those challenging times you have three choices: either you can let them define you, let them destroy you; or you can let them strengthen you.