ACCA2019-2020MA（F2）考试大纲，速看！

正确答案：
(b) There are several matters that Irroy will need to be aware of in relation to value added tax and corporation tax. These are set
out below.
Residence of subsidiary
Irroy will want to ensure that the subsidiary is treated as being resident in the Republic of Ireland. It will then pay corporation
tax on its profits at lower rates than in the UK. The country of incorporation usually claims taxing rights, but this is not by
itself sufficient. Irroy needs to be aware that a company can be treated as UK resident by virtue of the location of its central
management and control. This is usually defined as being where the board of directors meets to make strategic decisions. As
a result, Irroy needs to ensure that board meetings are conducted outside the UK.
If Green Limited is treated as being UK resident, it will be taxed in the UK on its worldwide income, including that arising in
the Republic of Ireland. However, as it will be conducting trading activities in the Republic of Ireland, Green Limited will also
be treated as being Irish resident as its activities in that country are likely to constitute a permanent establishment. Thus it
may also suffer tax in the Republic of Ireland as a consequence, although double tax relief will be available (see later).
A permanent establishment is broadly defined as a fixed place of business through which a business is wholly or partly carried
on. Examples of a permanent establishment include an office, factory or workshop, although certain activities (such as storage
or ancillary activities) can be excluded from the definition.
If Green Limited is treated as being an Irish resident company, any dividends paid to Aqua Limited will be taxed under
Schedule D Case V in the UK. Despite being non resident, Green Limited will still count as an associate of the existing UK
companies, and may affect the rates of tax paid by Aqua Limited and Aria Limited in the UK. However, as a non UK resident
company, Green Limited will not be able to claim losses from the UK companies by way of group relief.
Double tax relief
If Green Limited is treated as UK resident, corporation tax at UK rates will be payable on all profits earned. However, income
arising in the Republic of Ireland is likely to have been taxed in that country also by virtue of having a permanent
establishment located there. As the same profits have been taxed twice, double tax relief is available, either by reference to
the tax treaty between the UK and the Republic of Ireland, or on a unilateral basis, where the UK will give relief for the foreign
tax suffered.
If Green Limited is treated as an Irish resident company, it will pay tax in the Republic of Ireland, based on its worldwide
taxable profits. However, any repatriation of profits to the UK by dividend will be taxed on a receipts basis in the UK. Again,
double tax relief will be available as set out above.
Double tax relief is available against two types of tax. For payments made by Green Limited to Aqua Limited on which
withholding tax has been levied, credit will be given for the tax withheld. In addition, relief is available for the underlying tax
where a dividend is received from a foreign company in which Aqua Limited owns at least 10% of the voting power. The
underlying tax is the tax attributable to the relevant profits from which the dividend was paid.
Double tax relief is given at the lower rate of the UK tax and the foreign tax (withholding and underlying taxes) suffered.
Transfer pricing
Where groups have subsidiaries in other countries, they may be tempted to divert profits to subsidiaries which pay tax at lower
rates. This can be achieved by artificially changing the prices charged (known as the transfer price) between the group
companies. While they can do this commercially through common control, anti avoidance legislation seeks to correct this by
ensuring that for taxation purposes, profits on such intra-group transactions are calculated as if the transactions were carried
out on an arms length basis. Since 1 April 2004, this legislation can also be applied to transactions between UK group
companies.
If Green Limited is treated as a UK resident company, the group’s status as a small or medium sized enterprise means that
transfer pricing issues will not apply to transactions between Green Limited and the other UK group companies.
If Green Limited is an Irish resident company, transfer pricing issues will not apply to transactions between Green Ltd and the
UK resident companies because of the group’s status as a small or medium-sized enterprise and the existence of a double
tax treaty, based on the OECD model, between the UK and the Republic of Ireland.
Controlled foreign companies
Tax legislation exists to stop a UK company accumulating profits in a foreign subsidiary which is subject to a low tax rate.
Such a subsidiary is referred to as a controlled foreign company (CFC), and exists where:
(1) the company is resident outside the UK, and
(2) is controlled by a UK resident entity or persons, and
(3) pays a ‘lower level of tax’ in its country of residence.
A lower level of tax is taken to be less than 75% of the tax that would have been payable had the company been UK resident.
If Green Limited is an Irish resident company, it will be paying corporation tax at 12·5% so would appear to be caught by
the above rules and is therefore likely to be treated as a CFC.
Where a company is treated as a CFC, its profits are apportioned to UK resident companies entitled to at least 25% of its
profits. For Aqua Limited, which would own 100% of the shares in Green Limited, any profits made by Green Limited would
be apportioned to Aqua Limited as a deemed distribution. Aqua Limited would be required to self-assess this apportionment
on its tax return and pay UK tax on the deemed distribution (with credit being given for the Irish tax suffered).
There are some exemptions which if applicable the CFC legislation does not apply and no apportionments of profits will be
made. These include where chargeable profits of the CFC do not exceed ￡50,000 in an accounting period, or where the CFC
follows an acceptable distribution policy (distributing at least 90% of its chargeable profits within 18 months of the relevant
period).
Value added tax (VAT)
Green Limited will be making taxable supplies in the Republic of Ireland and thus (subject to exceeding the Irish registration
limit) liable to register for VAT there. If Green Limited is registered for VAT in the Republic of Ireland, then supplies of goods
made from the UK will be zero rated. VAT on the goods will be levied in the Republic of Ireland at a rate of 21%. Aqua Limited
will need to have proof of supply in order to apply the zero rate, and will have to issue an invoice showing Green Limited’s
Irish VAT registration number as well as its own. In the absence of such evidence/registration, Aqua Limited will have to treat
its transactions with Green Limited as domestic sales and levy VAT at the UK standard rate of 17·5%.
In addition to making its normal VAT returns, Aqua Limited will also be required to complete an EU Sales List (ESL) statement
each quarter. This provides details of the sales made to customers in the return period – in this case, Green Limited. Penalties
can be applied for inaccuracies or non-compliance.

正确答案：
(a) Of vital importance is the need for reliable information on which to base the decision regarding the potential investment within
Tomorrowland, since the lack of such information will only serve to increase the risk profile of GHG.
The strategic factors that ought to be considered prior to a decision being made to build and operate a hotel in Tomorrowland
are as follows:
The competition
The key notion here is that of the position of GHG relative to its competitors who may have a presence or intend to have a
presence in Tomorrowland. The strategic management accounting system should be capable of coping with changes that can
and will inevitably occur in a dynamic business environment. Hence it is crucial that changes such as, the emergence of a
new competitor, are detected and reflected within strategic plans at the earliest opportunity.
The government
The attitude of the government of Tomorrowland towards foreign organisations requires careful consideration as inevitably the
government will be the country’s largest supplier, employer, customer and investor. The directors need to recognise that the
political environment of Tomorrowland could change dramatically with a change in the national government.
Planning and control of operations within Tomorrowland
Planning and control of operations within Tomorrowland will inevitably be more difficult as GHG might not possess sufficient
knowledge of the business environment within Tomorrowland. Indeed their nearest hotel is at least 3,000 kilometres away.
It is vital the GHG gain such knowledge prior to commencing operations within Tomorrowland in order to avoid undue risks.
The sociological–cultural constraints
While it is generally recognised that there is a growing acceptability of international brands this might not be the case with
regard to Tomorrowland. The attitude towards work, managers (especially foreign nationals) and capitalist organisations could
severely impact on the degree of success achieved within Tomorrowland. In this respect it is vital that consideration is given
to recognition of the relationships in economic life including demand, price, wages, training, and rates of labour turnover and
absenteeism.
Resource utilisation
A primary consideration relates to whether or not to use local labour in the construction of the hotel. The perceived
‘remoteness’ of Tomorrowland might make it an unattractive proposition for current employees of GHG, thereby presenting the
directors of GHG with a significant problem.
Communication
Consideration needs to be given to the communication problems that arise between different countries and in this respect
Tomorrowland is probably no exception. Language barriers will inevitably exist and this needs to be addressed at the earliest
opportunity to minimise any risks to GHG.
The economic factors that ought to be considered prior to a decision being made to build and operate a hotel in Tomorrowland
are as follows:
Resource availability
The hotel should be designed having given due consideration to the prevailing climatic conditions within Tomorrowland which
might necessitate the use of specific types of building materials. It might well be the case that such building materials are not
available locally, or are in such scarce supply in which case local supply would prove to be uneconomic.
Another consideration relates to local labour being available and reliable in terms of its quality.
Currency stability/restrictions
The stability of the currency within Tomorrowland assumes critical significance because profit repatriation is problematic in
situations where those profits are made in an unstable currency or one that is likely to depreciate against the home currency,
thereby precipitating sizeable losses on exchange. Any currency restrictions need to be given careful consideration. For
example, it might be the case that hotel guests would be prohibited from paying accommodation bills in a foreign currency
which would be problematic if the local currency was weak.
Legislation
All local and International legislation should be given careful consideration. It might be the case that local legislation via
various licences or legal requirements favour local hotels.
Demand
The potential demand within Tomorrowland will be linked to the local economy. It is a developing economy and this may
bode well for GHG. However, again the need for reliable information about the size of the market, the extent of competition,
likely future trends etc is of fundamental importance.
Financing
An important decision lies in the availability and associated costs of financing in Tomorrowland which might not have mature
enough capital markets due to its developmental state. Hence GHG might need to finance using alternative currencies.
Note: Other relevant comments would be acceptable.

正确答案：
(b) Perfect Shopper currently has a relatively short upstream supply chain. They are bulk purchasers from established suppliers
of branded goods. Their main strength at the moment is to offer these branded goods at discounted prices to neighbourhood
shops that would normally have to pay premium prices for these goods.
In the upstream supply chain, the issue of branding is a significant one. At present, Perfect Shopper only provides branded
goods from established names to its customers. As far as the suppliers are concerned, Perfect Shopper is the customer and
the company’s regional warehouses are supplied as if they were the warehouses of conventional supermarkets. Perfect
Shopper might look at the following restructuring opportunities within this context:
– Examining the arrangements for the delivery of products from suppliers to the regional warehouses. At present this is in
the hands of the suppliers or contractors appointed by suppliers. It appears that when Perfect Shopper was established
it decided not to contract its own distribution. This must now be open to review. It is likely that competitors have
established contractual arrangements with logistics companies to collect products from suppliers. Perfect Shopper must
examine this, accompanied by an investigation into downstream distribution. A significant distribution contract would
probably include the branding of lorries and vans and this would provide an opportunity to increase brand visibility and
so tackle this issue at the same time.
– Contracting the supply and distribution of goods also offers other opportunities. Many integrated logistics contractors also
supply storage and warehousing solutions and it would be useful for Perfect Shopper to evaluate the costs of these.
Essentially, distribution, warehousing and packaging could be outsourced to an integrated logistics company and Perfect
Shopper could re-position itself as a primarily sales and marketing operation.
– Finally, Perfect Shopper must review how it communicates orders and ordering requirements with its suppliers. Their
reliance on supplier deliveries suggests that the relationship is a relatively straightforward one. There may be
opportunities for sharing information and allowing suppliers access to forecasted demand. There are many examples
where organisations have allowed suppliers access to their information to reduce costs and to improve the efficiency of
the supply chain as a whole.
The suggestions listed above assume that Perfect Shopper continues to only supply branded goods. Moving further upstream
in the supply chain potentially moves the company into the manufacture and supply of goods. This will raise a number of
significant issues about the franchise itself.
At present Perfect Shopper has, by necessity, concentrated on branded goods. It has not really had to understand how these
goods sell in specific locations because it has not been able to offer alternatives. The content of the standing order reflects
how the neighbourhood shop wishes to compete in its locality. However, if Perfect Shopper decides to commission its own
brand then the breadth of products is increased. Neighbourhood shops would be able to offer ‘own brand’ products to compete
with supermarkets who also focus on own brand products. It would also increase the visibility of the brand. However, Perfect
Shopper must be sure that this approach is appropriate as a whole. It could easily produce an own brand that reduces the
overall image of the company and hence devalues the franchise. Much more research is needed to assess the viability ofproducing ‘own brand’ goods.