点击查看：2020年广东省9月ACCA考试成绩查询时间

正确答案：
(b) Gift of the share portfolio to Avril
Inheritance tax
The gift would be a potentially exempt transfer at market value. No inheritance tax would be due at the time of the gift.
Capital gains tax
The gift would be a disposal by Crusoe deemed to be made at market value for the purposes of capital gains tax. No gain
would arise as the deemed proceeds will equal Crusoe’s base cost of probate value.
Stamp duty
There is no stamp duty on a gift of shares for no consideration.
Strategy to avoid a possible tax liability in the future
Crusoe should enter into a deed of variation directing the administrators to transfer the shares to Avril rather than to him. This
will not be regarded as a gift by Crusoe. Instead, provided the deed states that it is intended to be effective for inheritance tax
purposes, it will be as if Noland had left the shares to Avril in a will.
This strategy is more tax efficient than Crusoe gifting the shares to Avril as such a gift would be a potentially exempt transfer
and inheritance tax may be due if Crusoe were to die within seven years.
The deed of variation must be entered into by 1 October 2009, i.e. within two years of the date of Noland’s death.

正确答案：
(b) Risk management strategies and Chen Products
Risk transference strategy
This would involve the company accepting a portion of the risk and seeking to transfer a part to a third party. Although an
unlikely possibility given the state of existing claims, insurance against future claims would serve to limit Chen’s potential
losses and place a limit on its losses. Outsourcing manufacture may be a way of transferring risk if the ourtsourcee can be
persuaded to accept some of the product liability.
Risk avoidance strategy
An avoidance strategy involves discontinuing the activity that is exposing the company to risk. In the case of Chen this would
involve ceasing production of Product 2. This would be pursued if the impact (hazard) and probability of incurring an
acceptable level of liability were both considered to be unacceptably high and there were no options for transference or
reduction.
Risk reduction strategy
A risk reduction strategy involves seeking to retain a component of the risk (in order to enjoy the return assumed to be
associated with that risk) but to reduce it and thereby limit its ability to create liability. Chen produces four products and it
could reconfigure its production capacity to produce proportionately more of Products 1, 3 and 4 and proportionately less of
Product 2. This would reduce Product 2 in the overall portfolio and therefore Chen’s exposure to its risks. This would need
to be associated with instructions to other departments (e.g. sales and marketing) to similarly reconfigure activities to sell
more of the other products and less of Product 2.
Risk acceptance strategy
A risk acceptance strategy involves taking limited or no action to reduce the exposure to risk and would be taken if the returns
expected from bearing the risk were expected to be greater than the potential liabilities. The case mentions that Product 2 is
highly profitable and it may be that the returns attainable by maintaining and even increasing Product 2’s sales are worth the
liabilities incurred by compensation claims. This is a risk acceptance strategy.

正确答案：
(ii) Exercising of share options
The share option is not part of an approved scheme, and will not therefore enjoy the benefits of such a scheme. There
are three events with tax consequences – grant, exercise and sale.
Grant. If shares or options over shares are sold or granted at less than market value, an income tax charge can arise on
the difference between the price paid and the market value. [Weight v Salmon]. In addition, if options can be exercised
more than 10 years after the date of the grant, an employment income charge can arise. This is based on the market
value at the date of grant less the grant and exercise priced.
In Henry’s case, the options were issued with an exercise price equal to the then market value, and cannot be exercised
more than 10 years from the grant. No income tax charge therefore arises on grant.
Exercise. On exercise, the individual pays the agreed amount in return for a number of shares in the company. The price
paid is compared with the open market value at that time, and if less, the difference is charged to income tax. National
insurance also applies, and the company has to pay Class 1 NIC. If the company and shareholder agree, the national
insurance can be passed onto the individual, and the liability becomes a deductible expense in calculating the income
tax charge.
In Henry’s case on exercise, the difference between market value (￡14) and the price paid (￡1) per share will be taxed
as income. Therefore, ￡130,000 (10,000 x (￡14 – ￡1)) will be taxed as income. In addition, national insurance will
be chargeable on the company at 12·8% (￡16,640) and on Henry at the rate of 1% (￡1,300).
Sale. The base cost of the shares is taken to be the market value at the time of exercise. On the sale of the shares, any
gain or loss arising falls under the capital gains tax rules, and CGT will be payable on any gain. Business asset taper
relief will be available as the company is an unquoted trading company, but the relief will only run from the time that
the share options are exercised – i.e. from the time when the shares were acquired.
In Henry’s case, the sale of the shares will immediately follow the exercise of the option (6 days later). The sale proceeds
and the market value at the time of exercise are likely to be similar; thus little to no gain is likely to arise.

正确答案：C