ACCA证书考试需具备哪些条件

正确答案：
(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) (i) Currently there are many rules on how gains and losses on tangible non current assets should be reported and these
have traditionally varied from country to country. The main issues revolve around the reporting of depreciation,
disposal/revaluation gains and losses, and impairment losses. The reporting of such elements should take into account
whether the tangible non current assets have been revalued or held at historical cost. The problem facing standard
setters is where to report such gains and losses.The question is whether they should be reported as part of operating
activities or as ‘other gains and losses’.
Holding gains arising on the sale of tangible non current assets could be reported separately from operating results so
that the latter is not obscured by an asset realisation that reflects more a change in market prices than any increase in
the operating activity of the entity. Other changes in the carrying amounts of tangible non current assets will be reported
as part of the operating results. For example, the depreciation charge tries to reflect the consumption of the asset by the
entity and as such is not a holding loss. There may be cases where the depreciation charge does not reflect the
consumption of economic benefits. For example, the pattern and rate of depreciation could have been misjudged
because the asset’s useful life has been assessed incorrectly. In this case, when an asset is sold any excess or shortfall
of depreciation may need to be dealt with in the operating result.
Impairment is another factor to consider in reporting gains and losses on tangible non current assets. Impairment is
effectively accelerated depreciation. Impairment arises when the carrying amount of the asset is above its recoverable
amount. It follows therefore that any impairment loss should be reported as part of the operating result. Any losses on
disposal, to the extent that they represent impairment, could therefore be reported as part of the operating results. Any
losses which represent holding losses could be reported in ‘other gains and losses’. The difficulty will be differentiating
between holding losses and impairment losses. There will have to be clear and concise definitions of these terms or it
could lead to abuse by companies in their quest to maximise operating profits.
A distinction should be made between gains and losses arising on tangible non current assets as a result of revaluations
and those arising on disposal. The nature of the gain or loss is essentially the same although the timing and certainty
of the gain/loss is different. Therefore revaluation gains/losses may be reported in the ‘other gains and losses’ section.
Where an asset has been revalued, any loss on disposal that represents an impairment would be charged to operating
results and any remaining loss reported in ‘other gains and losses’.
Essentially, gains and losses should be reported on the basis of the characteristics of the gains and losses themselves.
Gains and losses with similar characteristics should be reported together thus helping the comparability of financial
performance nationally and internationally.

正确答案：D

At 31 March 2015, the deferred consideration of $12,650 would need to be discounted by 10% for one year to $11,500 (effectively deferring a finance cost of $1,150). The total amount credited to profit or loss would be $24,150 (12,650 + 11,500).

正确答案：
(b) (i) Principal audit procedures – measurement of share-based payment expense
– Obtain management calculation of the expense and agree the following from the calculation to the contractual
terms of the scheme:
– Number of employees and executives granted options
– Number of options granted per employee
– The official grant date of the share options
– Vesting period for the scheme
– Required performance conditions attached to the options.
– Recalculate the expense and check that the fair value has been correctly spread over the stated vesting period.
– Agree fair value of share options to specialist’s report and calculation, and evaluate whether the specialist report is
a reliable source of evidence.
– Agree that the fair value calculated is at the grant date.
Tutorial note: A specialist such as a chartered financial analyst would commonly be used to calculate the fair value
of non-traded share options at the grant date, using models such as the Black-Scholes Model.
– Obtain and review a forecast of staffing levels or employee turnover rates for the duration of the vesting period, and
scrutinise the assumptions used to predict level of staff turnover.
– Discuss previous levels of staff turnover with a representative of the human resources department and query why
0% staff turnover has been predicted for the next three years.
– Check the sensitivity of the calculations to a change in the assumptions used in the valuation, focusing on the
assumption of 0% staff turnover.
– Obtain written representation from management confirming that the assumptions used in measuring the expense
are reasonable.
Tutorial note: A high degree of scepticism must be used by the auditor when conducting the final three procedures
due to the management assumption of 0% staff turnover during the vesting period.