听说ACCA即将成为财务行业主流选择？一起来了解下吧！

正确答案：
(a) Inbound logistics: Handling and storing bulk orders delivered by suppliers and stored on large pallets in regional warehouses.
All inbound logistics currently undertaken by the food suppliers or by contractors appointed by these suppliers.
Operations: Splitting bulk pallets into smaller packages, packing, sealing and storing these packages.
Outbound logistics: Delivery to neighbourhood shops using locally contracted distribution companies.
Marketing & Sales: Specially commissioned signs and personalised sales literature. Promotions and special offers.
Service: Specialist in-store display units for certain goods, three monthly meeting between franchisee and representative.

正确答案：
(b) The launch of any new business is a critical event and a marketing plan a vital ingredient in achieving launch success. Most
companies will associate a marketing plan with the ever-popular 4 Ps. However, the marketing mix can only be decided once
some fundamental marketing decisions have been taken. Firstly, the group need to clearly identify which segments of the
market they are seeking to attract. Segments are made up of groups of customers with similar needs and expectations. If they
are identifying the student market as an important segment they should recognise that there are very different segments within
this group. They are most likely to want to target those students willing and able to pay for a high quality meal and experience.
They are not in the market for low priced/fast food. This requires them to recognise how they are trying to position their
restaurant – high quality and moderate prices looks to be a combination, which will deliver an attractive service and added
value to the customer. The relationship between the customers’ perception of added value and the price charged is, in terms
of Bowman’s strategy clock, likely to be that of a focused differentiator.
For the Casa del Mediterraneo getting the product or service right will involve a complex co-ordination of many different
activities – from buying the right food through to delivering the orders efficiently. As a service, there may be many more things
that potentially can go wrong and it really does come down to the people delivering the service. This involves one of the
additional ‘P’s, involved in delivering services, namely processes, which together with the physical evidence in the shape of
the restaurant, will have a major say in the success or otherwise of the launch. Clearly, the place and the physical evidence
are one and the same thing and the right location will also affect the success of both the launch and the whole venture.
Pricing in a competitive market will be important and many upmarket restaurants price on the basis of what the market will
bear. There needs to be a clear relationship between the price and the value offered. Finally, promotion is perhaps the key
element in the effective launch of the new restaurant. There will need to be a correct choice of media to reach the targetaudience including the use of web-based advertising to get the restaurant known.

正确答案：
2 Crocus Co
(a) (i) Forensic accounting utilises accounting, auditing, and investigative skills to conduct an examination into a company’s
financial statements. The aim of forensic accounting is to provide an accounting analysis that is potentially suitable for
use in court. Forensic accounting is an umbrella term encompassing both forensic investigations and forensic audits. It
includes the audit of financial information to prove or disprove a fraud, the interview process used during an
investigation, and the act of serving as an expert witness.
Tutorial note: Forensic accounting can be used in a very wide range of situations, e.g. settling monetary disputes in
relation to a business closure, marriage break up, insurance claim, etc. Credit will be awarded for any reasonable
examples provided.
(ii) A forensic investigation is a process whereby a forensic accountant carries out procedures to gather evidence, which
could ultimately be used in legal proceedings or to settle disputes. This could include, for example, an investigation into
money laundering. A forensic investigation involves many stages (similar to an audit), including planning, evidence
gathering, quality control reviews, and finally results in the production of a report.
(iii) Forensic auditing is the specific use of audit procedures within a forensic investigation to find facts and gather evidence,
usually focused on the quantification of a financial loss. This could include, for example, the use of analytical
procedures, and substantive procedures to determine the amount of an insurance claim.

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.