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正确答案：
(c) Mr Hogg’s belief that employing child labour is ‘always ethically wrong’
Deontological perspective:
In the case scenario, Mr Hogg is demonstrating a deontological position on child labour by saying that it is ‘always’ wrong.
He is adopting an absolutist rather than a relativist or situational stance in arguing that there are no situations in which child
labour might be ethically acceptable. The deontological view is that an act is right or wrong in itself and does not depend
upon any other considerations (such as economic necessity or the extent of the child’s willingness to work). If child labour is
wrong in one situation, it follows that it is wrong in all situations because of the Kantian principle of generalisability (in the
categorical imperative). Because child labour is wrong and potentially exploitative in some situations, the deontological
position says that it must be assumed to be wrong in all situations. The fact that it may cause favourable outcomes in some
situations does not make it ethically right, because the deontological position is not situational and the quality of the outcome
is not taken into account.
Teleological perspective:
According to the teleological perspective, an act is right or wrong depending on the favourableness of the outcome. It is
sometimes called the consequentialist perspective because the consequences of the action are considered more important
than the act itself.
In the teleological perspective, ethics is situational and not absolute. Therefore child labour is morally justified if the outcome
is favourable. The economic support of a child’s family by provision of wages for family support might be considered to be a
favourable outcome that justifies child labour. There is an ethical trade-off between the importance of the family income from
child labour and the need to avoid exploitation and interfere with the child’s education. Education is clearly important but
family financial support might be a more favourable outcome, at least in the short term, and if so, this would justify the child
working rather than being in school. For HPC, child labour is likely to be cheaper than adult labour but will alienate European
buyers and be in breach of its code of ethics. Child labour may be ethically acceptable if the negative consequences can be
addressed and overcome.
[Tutorial note: other, equally relevant points made in evaluating Mr Hogg’s opinion will be valid. The texts discuss teleology
in terms of utilitarianism and egoism. Although this distinction is not relevant to the question, candidates should not be
penalised for introducing the distinction if the other points raised are relevant]

正确答案：

(ii) The budgeted corporation tax liability for the year ending 30 June 2008
Following the proposed restructuring, Rapier Ltd will be carrying on four separate trades. The current year loss arising
in the Dirk trade can be offset against its total profits. Its three subsidiaries will be dormant and will not be associates
for the purpose of determining the rate of corporation tax.

正确答案：

正确答案：
(c) (1) Acquisition of shares
Status
The acquisition of shares in Tagus LDA will add another associated company to the group. This may have an adverse
effect on the rates of corporation tax paid by the two existing group companies, particularly Tay Limited.
Taxation of profits
Profits will be taxed in Portugal. Any profits remitted to the UK as dividends will be taxable as Schedule D Case V income,
but will attract double tax relief. Double tax relief will be available against two types of tax suffered in Portugal. Credit
will be given for any tax withheld on payments from Tagus LDA to Tay Limited and relief will also be available for the
underlying tax as Tay Limited owns at least 10% of the voting power of Tagus LDA. 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.
Losses
As Tagus LDA is a non-UK resident company, losses arising in Tagus LDA cannot be group relieved against profits of the
two UK companies. Similarly, any UK trading losses cannot be used against profits generated by Tagus LDA.
(2) Acquisition of assets
Status
The business of Tagus will be treated as a branch of Tay Limited i.e. an extension of the UK company’s activities. The
number of associated companies will be unaffected.
Taxation of profits
Tay Limited will be treated as having a permanent establishment in Portugal. Profits attributable to the Tagus business
will thus still be taxed in Portugal. In addition, the profits will be taxed in the UK as trading income. Double tax relief
will be available for the tax already suffered in Portugal at the lower of the two rates.
Capital allowances will be available. As the assets in question will not previously have been subject to a claim for UK
capital allowances, there will be no cost restriction and the consideration attributable to each asset will form. the basis
for the capital allowance claim.
Losses
The Tagus trade is part of Tay Limited’s trade, so any losses incurred by the Portuguese trade will automatically be offset
against the trading profits of the UK trade, and vice versa.