带你看看！报考ACCA资格需要满足什么学历条件？

正确答案：C
83,600 + 18,000 – 4,500 = 97,100

正确答案：
(b) Essentially, Universal is a one product or service company selling its services into two main customer segments in the housing
market. From the performance information provided in Table 1, the company has achieved impressive rates of growth over
the 2001–4 period and this growth has come almost exclusively from private house owners. Universal is in the replacement
market. Its customers are looking to replace existing roofing systems with low maintenance/high attractiveness Universal
systems. To date growth has been exclusively within one region and been achieved by growing the area served through
investment in showrooms and depots.
Universal has chosen to grow its business through a differentiation focus strategy. It has identified a niche not served by the
major PVC doors and windows installers and poorly served by small independent installers. The value chain analysis
discussed above has shown the ways in which Universal has successfully distinguished itself from its competitors. Growth
has been through increasing its market penetration of one particular region. Such is the size of the private house owner market
and the lack of effective competition that the company has achieved a significant share of the market in its particular region.
However, in national terms, with 1% of the available market, Universal is a small operator. What is clear from the sales figures
is that as the firm grows bigger the relative rate of growth inevitably slows down, so that by 2004 it has an annual growth of
27% – still impressive by most companies standards. The move into supplying the commercial housing market has been
successful, but the share of total sales seems to have stabilised at around 5%. Universal clearly is finding it difficult to commit
sufficient new resources to this sector while coping with the growth from the domestic housing sector. Direct labour and other
direct costs seem to be a reasonable proportion of sales and predictably grow with the number of installation teams. Overall,
the gross margin, which sustains sales, marketing and overhead expenses, is moving in the right direction with a gross margin
of 52·6% achieved in 2004.
Labour, not surprisingly in a service business, consumes a considerable amount of costs. If one combines the direct labour
with the commission costs of sales canvassers and representatives together with salaries to staff in head office, one is in a
business where well over 50% of costs are attributable to people. Equally important is the fact that over 80% of the staff
employed by Universal is paid by results. This has significant consequences for the structure of reward systems and the
training and development of staff looking to maximise their incomes through either their individual or team performance.
Clearly, Universal sees no incompatibility between a reward system dominated by payments by results and the delivery of a
quality service differentiating it from its competitors.
Marketing has grown considerably over the period and reflects the recruitment of Mick Hendry as Sales and Marketing Director
in 2002. The marketing and sales model is very much one influenced by the one used by large PVC installers of doors and
windows. Here there is a heavy emphasis on direct selling techniques supported by increasing levels of advertising. Universal
sells to its customers directly and therefore avoids the costs and channel complications of using third parties to provide its
services. In many ways the direct selling techniques used are a very well established way of reaching the customer. Elements
of the marketing mix may be influenced by changes in communication technology, but the nature of the service requires
effective face-to-face contact with the customer. Sales to private house owners using credit generates significant finance
commission and is an important source of extra margin to Universal. Often in businesses depending on significant amounts
of credit sales the sales representative receives significant reward for selling a finance arrangement to the customer.
In terms of net profit achieved, 2001 and 2002 represents a significant change and, as argued in the scenario, this reflects
the recruitment of the Sales and Marketing Director. The achievement of this ‘step change’ in sales required commensurate
increases in most costs, but it is the significant increase in sales costs that explains the losses experienced in 2002. Sales
costs as a proportion of total sales rose from 14% in 2001 to almost 34% in 2002.
Particularly significant is the increase in sales commissions paid. The detailed changes in the way commission is paid is not
given in the case scenario, but it seems likely to reflect the previous experience of the Sales and Marketing Director in a closely
related industry. Similar levels of sales costs are incurred in 2003 and 2004 but the increase in sales, improvement in gross
margin and slower rate of growth in commissions paid explain the improved return on sales from –6·7% in 2002 to 4·2%
in 2003 and 5·8% in 2004.
Equally significant is the growth in showrooms and depots to support the growth in sales. Each additional facility costs in the
order of ￡30K with significant additions to costs in terms of staff and stock. Overall the performance of Universal over the
2001–2004 period is of a company achieving high rates of growth, incurring significant costs in so doing and moving into
modest levels of profit over the period. Its cost structure reflects the service it provides and the staff and reward systemsenabling the service to be provided.

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.