福建省大学生在校期间备考ACCA有什么优势?

3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans to

expand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell her

shares back to the company. Once the purchase of her shares has taken place, the company intends to establish a

number of branches overseas and acquire a shareholding in a number of companies that are resident and trade in

overseas countries.

The following information has been obtained from client files and meetings with the parties involved.

Acrux Ltd:

– An unquoted UK resident company.

– Share capital consists of 50,000 ordinary shares issued at ￡1·90 per share in July 2000.

– None of the other shareholders has any connection with Spica.

The purchase of own shares:

– The company will purchase all of Spica’s shares for ￡8 per share.

– The transaction will take place by the end of 2008.

Spica:

– Purchased 8,000 shares in Acrux Ltd for ￡2 per share on 30 September 2003.

– Has no income in the tax year 2008/09.

– Has chargeable capital gains in the tax year 2008/09 of ￡3,800.

– Has houses in the UK and the country of Solaris and divides her time between them.

Investment in non-UK resident companies:

– Acrux Ltd will acquire between 15% and 20% of each of the non-UK resident companies.

– The companies will not be controlled foreign companies as the rates of tax in the overseas countries will be

between 23% and 42%.

– There may or may not be a double tax treaty between the UK and the overseas countries in which the companies

are resident. Where there is a treaty, it will be based on the OECD model treaty.

– None of the countries concerned levy withholding tax on dividends paid to UK companies.

– The directors of Acrux Ltd are concerned that the rate of tax suffered on the profits of the overseas companies

will be very high as they will be taxed in both the overseas country and in the UK.

Required:

(a) (i) Prepare detailed calculations to determine the most beneficial tax treatment of the payment Spica will

receive for her shares; (7 marks)

6 (a) Explain the term ‘money laundering’. (3 marks)

(b) Briefly discuss how stakeholder groups (other than management and employees) may be rewarded for ‘good’

performance. (4 marks)

4 Coral is the owner and managing director of Reef Ltd. She is considering the manner in which she will make her first

pension contributions. In November 2007 she inherited her mother’s house in the country of Kalania.

The following information has been extracted from client files and from telephone conversations with Coral.

Coral:

– 1972 – Born in the country of Kalania. Her father, who died in 2002, was domiciled in Kalania.

– 1999 – Moved to the UK and has lived and worked here since then.

– 2001 – Subscribed for 100% of the ordinary share capital of Reef Ltd.

– Intends to sell Reef Ltd and return to live in the country of Kalania in 2012.

– No income apart from that received from Reef Ltd.

Reef Ltd:

– A UK resident company with annual profits chargeable to corporation tax of approximately ￡70,000.

– Four employees including Coral.

– Provides scuba diving lessons to members of the public.

Payments from Reef Ltd to Coral in 2007/08:

– Director’s fees of ￡460 per month.

– Dividends paid of ￡14,250 in June 2007 and ￡14,250 in September 2007.

Pension contributions:

– Coral has not so far made any pension contributions in the tax year 2007/08 but wishes to make gross pension

contributions of ￡9,000.

– The contributions are to be made by Reef Ltd or Coral or a combination of the two in such a way as to minimise

the total after tax cost.

– Any contributions made by Coral will be funded by an additional dividend from Reef Ltd.

House in the country of Kalania:

– Beachfront property with potential rental income of ￡550 per month after deduction of allowable expenditure.

– Coral will use it for holidays for two months each year.

The tax system in the country of Kalania:

– No capital gains tax or inheritance tax.

– Income tax at 8% on income arising in the country of Kalania.

– No double tax treaty with the UK.

Required:

(a) With the objective of minimising the total after tax cost, advise Coral as to whether the gross pension

contributions of ￡9,000 should be made:

– wholly by Reef Ltd; or

– by Coral to the extent that they are tax allowable with the balance made by Reef Ltd.

Your answer should include supporting calculations where necessary. (9 marks)