(b) Draft a report as at today’s date advising Cutlass Inc on its proposed activities. The report should cover the

following issues:

(i) The rate at which the profits of Cutlass Inc will be taxed. This section of the report should explain:

– the company’s residency position and what Ben and Amy would have to do in order for the company

to be regarded as resident in the UK under the double tax treaty;

– the meaning of the term ‘permanent establishment’ and the implications of Cutlass Inc having a

permanent establishment in Sharpenia;

– the rate at which the profits of Cutlass Inc will be taxed on the assumption that it is resident in the

UK under the double tax treaty and either does or does not have a permanent establishment in

Sharpenia. (9 marks)