(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.

考题 (c) (i) State the date by which Thai Curry Ltd’s self-assessment corporation tax return for the year ended30 September 2005 should be submitted, and advise the company of the penalties that will be due ifthe return is not submitted until 31 May 2007. (3 marks)(ii) State the date by which Thai Curry Ltd’s corporation tax liability for the year ended 30 September 2005should be paid, and advise the company of the interest that will be due if the liability is not paid until31 May 2007. (3 marks)

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考题 Assume that the corporation tax rates for the financial year 2004 apply throughout.(b) Explain the corporation tax (CT) and value added tax (VAT) issues that Irroy should be aware of, if sheproceeds with her proposal for the Irish subsidiary, Green Limited. Your answer should clearly identify thosefactors which will determine whether or not Green Limited is considered UK resident or Irish resident andthe tax implications of each alternative situation.You need not repeat points that are common to each situation. (16 marks)

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考题 (c) Assuming that she will survive until July 2009, advise on the lifetime inheritance tax (IHT) planningmeasures that could be undertaken by Debbie, quantifying the savings that can be made. (7 marks)For this question you should assume that the rates and allowances for 2004/05 apply throughout.

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考题 (c) Without changing the advice you have given in (b), or varying the terms of Luke’s will, explain how Mabelcould further reduce her eventual inheritance tax liability and quantify the tax saving that could be made.(3 marks)The increase in the retail prices index from April 1984 to April 1998 is 84%.You should assume that the rates and allowances for the tax year 2005/06 will continue to apply for theforeseeable future.

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考题 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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考题 (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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考题 (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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考题 (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)

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考题 (b) Explain the advantages from a tax point of view of operating the new business as a partnership rather thanas a company whilst it is making losses. You should calculate the tax adjusted trading loss for the yearending 31 March 2008 for both situations and indicate the years in which the loss relief will be obtained.You are not required to prepare any other supporting calculations. (10 marks)

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考题 (c) Outline the ways in which Arthur and Cindy can reduce their income tax liability by investing in unquotedshares and recommend, with reasons, which form. of investment best suits their circumstances. You are notrequired to discuss the qualifying conditions applicable to the investment vehicle recommended. (5 marks)You should assume that the income tax rates and allowances for the tax year 2005/06 apply throughout thisquestion

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考题 (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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考题 (c) Prepare brief notes for the proposed meeting with Charles and Jane. Clearly identify the further informationyou would need in order to advise them more fully and suggest appropriate personal financial planningprotection products, in respect of both death and serious illness. (9 marks)You should assume that the income tax rates and allowances for the tax year 2005/06 and the corporation taxrates for the financial year 2005 apply throughout this question.

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考题 (c) Explain the capital gains tax (CGT) and income tax (IT) issues Paul and Sharon should consider in decidingwhich form. of trust to set up for Gisella and Gavin. You are not required to consider inheritance tax (IHT) orstamp duty land tax (SDLT) issues. (10 marks)You should assume that the tax rates and allowances for the tax year 2005/06 apply throughout this question.

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考题 (ii) Assuming the new structure is implemented with effect from 1 August 2006, calculate the level ofmanagement charge that should be made by Bold plc to Linden Limited for the year ended 31 July2007, so as to minimise the group’s overall corporation tax (CT) liability for that year. (2 marks)

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考题 (iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of inserting Bold plc asa holding company and identify any planning actions that can be taken to defer or minimise these taxcosts. (4 marks)You should assume that the corporation tax rates for the financial year 2005 and the income tax ratesand allowances for the tax year 2005/06 apply throughout this question.

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考题 (ii) Calculate the corporation tax (CT) payable by Tay Limited for the year ended 31 March 2006, takingadvantage of all available reliefs. (3 marks)

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考题 (iii) The extent to which Amy will be subject to income tax in the UK on her earnings in respect of dutiesperformed for Cutlass Inc and the travel costs paid for by that company. (5 marks)Appropriateness of format and presentation of the report and the effectiveness with which its advice iscommunicated. (2 marks)Note:You should assume that the income tax rates and allowances for the tax year 2006/07 and the corporation taxrates and allowances for the financial year 2006 apply throughout this questio

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考题 (iii) The effect of the restructuring on the group’s ability to recover directly and non-directly attributable inputtax. (6 marks)You are required to prepare calculations in respect of part (ii) only of this part of this question.Note: – You should assume that the corporation tax rates and allowances for the financial year 2006 applythroughout this question.

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考题 (b) The directors of Carver Ltd are aware that some of the company’s shareholders want to realise the value in theirshares immediately. Accordingly, instead of investing in the office building or the share portfolio they areconsidering two alternative strategies whereby, following the sale of the company’s business, a payment will bemade to the company’s shareholders.(i) Liquidate the company. The payment by the liquidator would be ￡126 per share.(ii) The payment of a dividend of ￡125 per share following which a liquidator will be appointed. The paymentby the liquidator to the shareholders would then be ￡1 per share.The company originally issued 20,000 ￡1 ordinary shares at par value to 19 members of the Cutler family.Following a number of gifts and inheritances there are now 41 shareholders, all of whom are family members.The directors have asked you to attend a meeting to set out the tax implications of these two alternative strategiesfor each of the two main groups of shareholders: adults with shareholdings of more than 500 shares and childrenwith shareholdings of 200 shares or less.Required:Prepare notes explaining:– the amount chargeable to tax; and– the rates of tax that will applyin respect of each of the two strategies for each of the two groups of shareholders ready for your meetingwith the directors of Carver Ltd. You should assume that none of the shareholders will have any capitallosses either in the tax year 2007/08 or brought forward as at 5 April 2007. (10 marks)Note:You should assume that the rates and allowances for the tax year 2006/07 will continue to apply for theforeseeable future.

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考题 (d) Evaluate the effect on Gerard of the changes to be made by Fizz plc to its performance related bonus scheme.You should ignore the effect of any pension contributions to be made by Gerard in the future, consider boththe value and timing of amounts received by Gerard and include relevant supporting calculations.(5 marks)Note: – You should assume that the income tax rates and allowances for the tax year 2006/07 apply throughoutthis question.

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考题 (c) The inheritance tax payable by Adam in respect of the gift from his aunt. (4 marks)Additional marks will be awarded for the appropriateness of the format and presentation of the memorandum andthe effectiveness with which the information is communicated. (2 marks)Note: you should assume that the tax rates and allowances for the tax year 2006/07 will continue to apply for theforeseeable future.

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考题 (c) Explanatory notes, together with relevant supporting calculations, in connection with the loan. (8 marks)Additional marks will be awarded for the appropriateness of the format and presentation of the schedules, theeffectiveness with which the information is communicated and the extent to which the schedules are structured ina logical manner. (3 marks)Notes: – you should assume that the tax rates and allowances for the tax year 2006/07 and for the financial yearto 31 March 2007 apply throughout the question.– you should ignore value added tax (VAT).

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考题 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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考题 (ii) Explain how the inclusion of rental income in Coral’s UK income tax computation could affect theincome tax due on her dividend income. (2 marks)You are not required to prepare calculations for part (b) of this question.Note: you should assume that the tax rates and allowances for the tax year 2006/07 and for the financial year to31 March 2007 will continue to apply for the foreseeable future.

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考题 (c) On the assumption that the administrators of Noland’s estate will sell quoted shares in order to fund theinheritance tax due as a result of his death, calculate the value of the quoted shares that will be available totransfer to Avril. You should include brief notes of your treatment of the house and the shares in Kurb Ltd.(9 marks)Note: you should assume that the tax rates and allowances for the tax year 2006/07 apply throughout thisquestion.

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考题 (b) Explain what effect the acquisition of Di Rollo Co will have on the planning of your audit of the consolidatedfinancial statements of Murray Co for the year ending 31 March 2008. (10 marks)

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考题 (ii) Write a letter to Donald advising him on the most tax efficient manner in which he can relieve the lossincurred in the year to 31 March 2007. Your letter should briefly outline the types of loss relief availableand explain their relative merits in Donald’s situation. Assume that Donald will have no source of incomeother than the business in the year of assessment 2006/07 and that any income he earned on a parttimebasis while at university was always less than his annual personal allowance. (9 marks)Assume that the corporation tax rates and allowances for the financial year 2004 and the income tax ratesand allowances for 2004/05 apply throughout this question.Relevant retail price index figures are:January 1998 159·5April 1998 162·6

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