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何谓HIRA?
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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 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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