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正确答案：
(c) The government of Happyland will be concerned by the negative impact on the environment. The growth in the number of
children born in Happyland will have raised the demand for disposable nappies as is evidenced from the market size data
contained in the question. In some countries disposable nappies make up around 4% of all household waste and can take
up to five hundred years to decompose! The government will be concerned by the fact that trees are being destroyed in order
to keep babies and infant children in nappies. The disposal costs incurred by the government in terms of landfill etc will be
very high, hence its green paper on the effect of non-biodegradable products in Happyland. The costs of such operations as
the landfill for such products will need to be funded out of increased taxation.
It might be beneficial for the directors of TMC to develop more eco-friendly products such as washable nappies which, by
definition, are recyclable many times over during the life of the ‘product’. Many parents are now changing to ‘real nappies’
because they work out cheaper and better for the environment than disposables.

正确答案：D
630,000 – 4,320 – 440

正确答案：

正确答案：
(b) Rate of tax on profits of non-UK resident investee companies
Undistributed profits
The companies will be subject to tax in the countries in which they are resident; this is because of their residency status or
because they have a permanent establishment in that country. Undistributed profits will not be taxed in the UK.
The rate of tax on undistributed profits will therefore be the rate of tax in the country of residency of the respective companies.
Distributed profits with double tax treaty
The dividends received by Acrux Ltd from each of the overseas companies will be grossed up in respect of underlying tax (the
overseas corporation tax paid on the distributed profits) because Acrux Ltd will own at least 10% of the overseas companies.
The gross amount will then be included in Acrux Ltd’s profits chargeable to corporation tax.
The treaty will provide double tax relief in the UK for the overseas tax suffered in respect of each dividend up to a maximum
of the UK tax on the grossed up overseas dividend. As a result of the double tax relief, the overall rate of tax suffered will be
the higher of the UK rate paid by Acrux Ltd and the overseas tax rate borne by the overseas company.
Where the rate of overseas tax in respect of a particular dividend exceeds the rate of corporation tax in the UK, excess foreign
tax will arise. This can be relieved, via onshore pooling, against the UK tax due on those dividends where the rate of tax in
the UK exceeds the rate overseas. This will reduce the overall rate of tax suffered on the total overseas profits of the overseas
companies as a whole.
Distributed profits with no double tax treaty
Where there is no double tax treaty, unilateral double tax relief will be available in the UK. This relief will operate in the same
way as double tax relief under a double tax treaty such that the overall rate of tax on each dividend will be the higher of the
UK rate paid by Acrux Ltd and the overseas rate borne by the overseas company. Relief via onshore pooling will also be
available.