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(d) Explain whether or not Dovedale Ltd, Hira Ltd and Atapo Inc can register as a group for the purposes of value
added tax. (3 marks)
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更多 “ (d) Explain whether or not Dovedale Ltd, Hira Ltd and Atapo Inc can register as a group for the purposes of valueadded tax. (3 marks) ” 相关考题
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In January 2008 Arti entered in a contractual agreement with Bee Ltd to write a study manual for an international accountancy body’s award. The manual was to cover the period from September 2008 till June 2009, and it was a term of the contract that the text be supplied by 30 June 2008 so that it could be printed in time for September. By 30 May, Arti had not yet started on the text and indeed he had written to Bee Ltd stating that he was too busy to write the text.Bee Ltd was extremely perturbed by the news, especially as it had acquired the contract to supply all of theaccountancy body’s study manuals and had already incurred extensive preliminary expenses in relation to the publication of the new manual.Required:In the context of the law of contract, advise Bee Ltd whether they can take any action against Arti.(10 marks)
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3 Moffat Ltd, which commenced trading on 1 December 2002, supplies and fits tyres and exhaust pipes and servicesmotor vehicles at thirty locations. The directors and middle management are based at the Head Office of Moffat Ltd.Each location has a manager who is responsible for day-to-day operations and is supported by an administrativeassistant. All other staff at each location are involved in fitting and servicing operations.The directors of Moffat Ltd are currently preparing a financial evaluation of an investment of ￡2 million in a new ITsystem for submission to its bank. They are concerned that sub-optimal decisions are being made because the currentsystem does not provide appropriate information throughout the organisation. They are also aware that not all of thebenefits from the proposed investment will be quantitative in nature.Required:(a) Explain the characteristics of THREE types of information required to assist in decision-making at differentlevels of management and on differing timescales within Moffat Ltd, providing TWO examples of informationthat would be appropriate to each level. (10 marks)
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(b) Identify and explain THREE approaches that the directors of Moffat Ltd might apply in assessing theQUALITATIVE benefits of the proposed investment in a new IT system. (6 marks)
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(ii) Comment briefly on the use of its own tree plantations as a source of raw materials by Our Timbers Ltd.(3 marks)
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(b) Advise the management of SCC Ltd of THREE strategies that should be considered in order to improve thefuture performance of SCC Ltd. (6 marks)
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(b) Calculate the corporation tax (CT) liabilities for Alantech Ltd, Boron Ltd and Bubble Ltd for the year ending31 December 2004 on the assumption that loss reliefs are taken as early as possible. (9 marks)
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(c) Advise Alan on the proposed disposal of the shares in Mobile Ltd. Your answer should include calculationsof the potential capital gain, and explain any options available to Alan to reduce this tax liability. (7 marks)
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(ii) Briefly outline the tax consequences for Henry if the types of protection identified in (i) were to beprovided for him by Happy Home Ltd compared to providing them for himself. You are not required todiscuss the corporation tax (CT) consequences for Happy Home Ltd. (4 marks)
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3 On 1 January 2007 Dovedale Ltd, a company with no subsidiaries, intends to purchase 65% of the ordinary sharecapital of Hira Ltd from Belgrove Ltd. Belgrove Ltd currently owns 100% of the share capital of Hira Ltd and has noother subsidiaries. All three companies have their head offices in the UK and are UK resident.Hira Ltd had trading losses brought forward, as at 1 April 2006, of ￡18,600 and no income or gains against whichto offset losses in the year ended 31 March 2006. In the year ending 31 March 2007 the company expects to makefurther tax adjusted trading losses of ￡55,000 before deduction of capital allowances, and to have no other incomeor gains. The tax written down value of Hira Ltd’s plant and machinery as at 31 March 2006 was ￡96,000 andthere will be no fixed asset additions or disposals in the year ending 31 March 2007. In the year ending 31 March2008 a small tax adjusted trading loss is anticipated. Hira Ltd will surrender the maximum possible trading lossesto Belgrove Ltd and Dovedale Ltd.The tax adjusted trading profit of Dovedale Ltd for the year ending 31 March 2007 is expected to be ￡875,000 andto continue at this level in the future. The profits chargeable to corporation tax of Belgrove Ltd are expected to be￡38,000 for the year ending 31 March 2007 and to increase in the future.On 1 February 2007 Dovedale Ltd will sell a small office building to Hira Ltd for its market value of ￡234,000.Dovedale Ltd purchased the building in March 2005 for ￡210,000. In October 2004 Dovedale Ltd sold a factoryfor ￡277,450 making a capital gain of ￡84,217. A claim was made to roll over the gain on the sale of the factoryagainst the acquisition cost of the office building.On 1 April 2007 Dovedale Ltd intends to acquire the whole of the ordinary share capital of Atapo Inc, an unquotedcompany resident in the country of Morovia. Atapo Inc sells components to Dovedale Ltd as well as to othercompanies in Morovia and around the world.It is estimated that Atapo Inc will make a profit before tax of ￡160,000 in the year ending 31 March 2008 and willpay a dividend to Dovedale Ltd of ￡105,000. It can be assumed that Atapo Inc’s taxable profits are equal to its profitbefore tax. The rate of corporation tax in Morovia is 9%. There is a withholding tax of 3% on dividends paid tonon-Morovian resident shareholders. There is no double tax agreement between the UK and Morovia.Required:(a) Advise Belgrove Ltd of any capital gains that may arise as a result of the sale of the shares in Hira Ltd. Youare not required to calculate any capital gains in this part of the question. (4 marks)
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(b) Explain by reference to Hira Ltd’s loss position why it may be beneficial for it not to claim any capitalallowances for the year ending 31 March 2007. Support your explanation with relevant calculations.(6 marks)
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(c) Calculate the expected corporation tax liability of Dovedale Ltd for the year ending 31 March 2007 on theassumption that all available reliefs are claimed by Dovedale Ltd but that Hira Ltd will not claim any capitalallowances in that year. (4 marks)
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(d) Explain how Gloria would be taxed in the UK on the dividends paid by Bubble Inc and the capital gains taxand inheritance tax implications of a future disposal of the shares. Clearly state, giving reasons, whether ornot the payment made to Eric is allowable for capital gains tax purposes. (9 marks)You should assume that the rates and allowances for the tax year 2005/06 apply throughout this question.
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(ii) The UK value added tax (VAT) implications for Razor Ltd of selling tools to and purchasing tools fromCutlass Inc; (2 marks)
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(b) Explain the corporation tax and value added tax (VAT) implications of the following aspects of the proposedrestructuring of the Rapier Ltd group.(i) The immediate tax implications of the restructuring. (6 marks)
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(ii) Explain whether or not Carver Ltd will become a close investment-holding company as a result ofacquiring either the office building or the share portfolio and state the relevance of becoming such acompany. (2 marks)
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3 Palm plc recently acquired 100% of the ordinary share capital of Nikau Ltd from Facet Ltd. Palm plc intends to useNikau Ltd to develop a new product range, under the name ‘Project Sabal’. Nikau Ltd owns shares in a non-UKresident company, Date Inc.The following information has been extracted from client files and from a meeting with the Finance Director of Palmplc.Palm plc:– Has more than 40 wholly owned subsidiaries such that all group companies pay corporation tax at 30%.– All group companies prepare accounts to 31 March.– Acquired Nikau Ltd on 1 November 2007 from Facet Ltd, an unrelated company.Nikau Ltd:– UK resident company that manufactures domestic electronic appliances for sale in the European Union (EU).– Large enterprise for the purposes of the enhanced relief available for research and development expenditure.– Trading losses brought forward as at 1 April 2007 of ￡195,700.– Budgeted taxable trading profit of ￡360,000 for the year ending 31 March 2008 before taking account of ‘ProjectSabal’.– Dividend income of ￡38,200 will be received in the year ending 31 March 2008 in respect of the shares in DateInc.‘Project Sabal’:– Development of a range of electronic appliances, for sale in North America.– Project Sabal will represent a significant advance in the technology of domestic appliances.– Nikau Ltd will spend ￡70,000 on staffing costs and consumables researching and developing the necessarytechnology between now and 31 March 2008. Further costs will be incurred in the following year.– Sales to North America will commence in 2009 and are expected to generate significant profits from that year.Shares in Date Inc:– Nikau Ltd owns 35% of the ordinary share capital of Date Inc.– The shares were purchased from Facet Ltd on 1 June 2003 for their market value of ￡338,000.– The sale was a no gain, no loss transfer for the purposes of corporation tax.– Facet Ltd purchased the shares in Date Inc on 1 March 1994 for ￡137,000.Date Inc:– A controlled foreign company resident in the country of Palladia.– Annual chargeable profits arising out of property investment activities are approximately ￡120,000, of whichapproximately ￡115,000 is distributed to its shareholders each year.The tax system in Palladia:– No taxes on income or capital profits.– 4% withholding tax on dividends paid to shareholders resident outside Palladia.Required:(a) Prepare detailed explanatory notes, including relevant supporting calculations, on the effect of the followingissues on the amount of corporation tax payable by Nikau Ltd for the year ending 31 March 2008.(i) The costs of developing ‘Project Sabal’ and the significant commercial changes to the company’sactivities arising out of its implementation. (8 marks)
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(b) Explain why making sales of Sabals in North America will have no effect on Nikau Ltd’s ability to recover itsinput tax. (3 marks)Notes: – you should assume that the corporation tax rates and allowances for the financial year to 31 March 2007will continue to apply for the foreseeable future.– you should ignore indexation allowance.
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(ii) The use of the trading loss of Tethys Ltd for the year ending 31 December 2008; (6 marks)
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(iii) Advice in connection with the sale of the manufacturing premises by Tethys Ltd; (7 marks)
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(iv) The stamp duty and/or stamp duty land tax payable by the Saturn Ltd group; (2 marks)Additional marks will be awarded for the appropriateness of the format and presentation of the memorandumand the effectiveness with which the information is communicated. (2 marks)
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(b) A summary of the information needed to satisfy our obligations under the money laundering legislation andany action that should be taken before agreeing to become tax advisers to the Saturn Ltd group. (5 marks)
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(c) (i) Explain how Messier Ltd can assist Galileo with the cost of relocating to the UK and/or provide him withinterest-free loan finance for this purpose without increasing his UK income tax liability; (3 marks)
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(ii) State, with reasons, whether Messier Ltd can provide Galileo with accommodation in the UK withoutgiving rise to a UK income tax liability. (2 marks)
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(ii) The answers to any questions that the potential investors may raise in connection with the maximumpossible investment, borrowing to finance the subscription and the implications of selling the shares.(7 marks)Note: you should assume that Vostok Ltd and its trade qualify for the purposes of the enterprise investmentscheme and you are not required to list the conditions that need to be satisfied by the company, itsshares or its business activities.
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(b) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of the new premises in theyear ending 31 March 2009 and explain, using illustrative calculations, how any additional recoverable inputtax will be calculated in future years. (5 marks)
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(b) Explain the need for a first time group auditor to analyse the group structure. (5 marks)
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