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正确答案：
(c) Fines and penalties
(i) Matters
■ $0·1 million represents 5·6% of profit before tax and is therefore material. However, profit has fallen, and
compared with prior year profit it is less than 5%. So ‘borderline’ material in quantitative terms.
■ Prior year amount was three times as much and represented 13·6% of profit before tax.
■ Even though the payments may be regarded as material ‘by nature’ separate disclosure may not be necessary if,
for example, there are no external shareholders.
■ Treatment (inclusion in cost of sales) should be consistent with prior year (‘The Framework’/IAS 1 ‘Presentation of
Financial Statements’).
■ The reason for the fall in expense. For example, whether due to an improvement in meeting health and safety
regulations and/or incomplete recording of liabilities (understatement).
■ The reason(s) for the breaches. For example, Albreda may have had difficulty implementing new guidelines in
response to stricter regulations.
■ Whether expenditure has been adjusted for in the income tax computation (as disallowed for tax purposes).
■ Management’s attitude to health and safety issues (e.g. if it regards breaches as an acceptable operational practice
or cheaper than compliance).
■ Any references to health and safety issues in other information in documents containing audited financial
statements that might conflict with Albreda incurring these costs.
■ Any cost savings resulting from breaches of health and safety regulations would result in Albreda possessing
proceeds of its own crime which may be a money laundering offence.
(ii) Audit evidence
■ A schedule of amounts paid totalling $0·1 million with larger amounts being agreed to the cash book/bank
statements.
■ Review/comparison of current year schedule against prior year for any apparent omissions.
■ Review of after-date cash book payments and correspondence with relevant health and safety regulators (e.g. local
authorities) for liabilities incurred before 30 September 2005.
■ Notes in the prior year financial statements confirming consistency, or otherwise, of the lack of separate disclosure.
■ A ‘signed off’ review of ‘other information’ (i.e. directors’ report, chairman’s statement, etc).
■ Written management representation that there are no fines/penalties other than those which have been reflected in
the financial statements.

正确答案：A

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.