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(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：
(b) Trying to focus on and improve the measurement of customer satisfaction.
This is a vital goal. Without monitoring and improvement of levels of customer satisfaction, an organisation will tend to
underachieve and is likely to have problems with its future effectiveness. Positive signals from performance measures made
earlier in the value chain are only relevant if they contribute to the ultimate requirement of customer satisfaction. Tunnel vision
and sub-optimisation are examples of measurement problems that may be reduced through recognition of the need for a
management focus on customer satisfaction. For example undue focus on the importance of maximising opening hours may
lead to lack of focus on other quality issues seen as important by customers.
Involving staff at all levels in the development and implementation of performance measures.
People are involved in the achievement of performance measures at all levels and in all aspects of an organisation. It is
important that all staff are willing to accept and work towards any performance measures that are developed to monitor their
part in the operation of the organisation and in the achievement of its objectives. This should help, for example, to reduce
gaming. At the sports complex an example of gaming might be, a deliberate attempt to understate the potential benefits of
maintaining the buildings in order to ensure that funds would be used for other purposes such as an increased advertising
budget. The directors of Astrodome Sports Ltd must recognise that leisure facilities that appear dated and in a poor state of
repair will cause customers to look for more aesthetically appealing alternatives.
Being flexible in the extent to which formal performance measures are relied on.
It is best to acknowledge that measures should not be relied on exclusively for control. A performance measure may give a
short-term signal that does not relate directly to actions that are taking place to improve the level of performance in the longer
term. To some extent, improved performance may be achieved through the informal interaction between individuals and
groups. This flexibility should help to reduce measure fixation and misrepresentation. For example the percentage increase in
the quantity of bowling equipment purchased is seen as necessarily implying increased demand for use of the bowling greens.
Giving consideration to the audit of the performance measurement system.
Actions that may be taken may include:
– Seeking expert interpretation of the performance measures in place. It is important that any audit is ‘free from bias’ and
conducted independently on an ‘arm’s length’ basis. Thus it is essential that such audits should be ‘free from the
influence’ of those personnel involved in the operation of the system.
– Maintaining a careful audit of the data used. Any assessment scheme is only as good as the data on which it is founded
and how this data is analysed and interpreted.
The above actions should help, in particular, to reduce the incidence and impact of measure fixation, misinterpretation and
gaming.
For example, an audit may show that the directors of Astrodome Sports Ltd are fixated on equipment availability and
misinterpret this as being the key to customer volume and high profitability. The audit may also provide evidence of gaming
such as a deliberate attempt to underplay the benefits of one course of action in order to release funds for use on some
alternative.

正确答案：

(b) Benchmarking at Marlow Fashion will not be an easy exercise. Marlow Fashion has developed a distinctive way of reaching
its markets that means direct comparisons will be hard to make. Certainly, it can carry out historical benchmarking in
comparing how its own processes and activities have improved, or otherwise, over a relevant period of time. Unfortunately,
this is likely to simply confirm worsening performance. It can compare its own key operations against the ‘best in class’;
regardless of which industry the excellent performer comes from. It could and should have been carrying out competitive
benchmarking on the retail side of the business where information should be more easily available. There may be an
opportunity to benchmark itself against firms that have gone through a similar crisis and achieved a successful turnaround.

In terms of the advantages and disadvantages, the willingness of managers responsible for a key area of performance to
compare themselves against relevant external performance measures should make them take responsibility for any changes
necessary. In Marlow Fashion, the acceptance that things have to be done differently will be the first stage in the turnaround.
Getting managers face-to-face with the problems, accepting responsibility for change and recognising that the necessary
changes are ‘doable’ is an important stage in creating a willingness to change. The disadvantages are that every organisation
and situation is different and there is no one best way. Marlow Fashion thought it had discovered the best way and this created
an unwillingness to change. There is also the danger that you are solving today’s problems with yesterday’s solutions. A good
competitor will be trying to maintain its competitive advantage through constantly improving its processes. It also has a vested
interest in trying to prevent its improvements from being revealed to its competitors. Also, many of the ‘softer’ processes –
typically involving people – are difficult if not impossible to replicate in another organisation. These advantages are to do with
culture and leadership and not easily transferable to another organisation and the context in which it is operating.