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正确答案：
(b) Rate of tax on profits of non-UK resident investee companies
Undistributed profits
The companies will be subject to tax in the countries in which they are resident; this is because of their residency status or
because they have a permanent establishment in that country. Undistributed profits will not be taxed in the UK.
The rate of tax on undistributed profits will therefore be the rate of tax in the country of residency of the respective companies.
Distributed profits with double tax treaty
The dividends received by Acrux Ltd from each of the overseas companies will be grossed up in respect of underlying tax (the
overseas corporation tax paid on the distributed profits) because Acrux Ltd will own at least 10% of the overseas companies.
The gross amount will then be included in Acrux Ltd’s profits chargeable to corporation tax.
The treaty will provide double tax relief in the UK for the overseas tax suffered in respect of each dividend up to a maximum
of the UK tax on the grossed up overseas dividend. As a result of the double tax relief, the overall rate of tax suffered will be
the higher of the UK rate paid by Acrux Ltd and the overseas tax rate borne by the overseas company.
Where the rate of overseas tax in respect of a particular dividend exceeds the rate of corporation tax in the UK, excess foreign
tax will arise. This can be relieved, via onshore pooling, against the UK tax due on those dividends where the rate of tax in
the UK exceeds the rate overseas. This will reduce the overall rate of tax suffered on the total overseas profits of the overseas
companies as a whole.
Distributed profits with no double tax treaty
Where there is no double tax treaty, unilateral double tax relief will be available in the UK. This relief will operate in the same
way as double tax relief under a double tax treaty such that the overall rate of tax on each dividend will be the higher of the
UK rate paid by Acrux Ltd and the overseas rate borne by the overseas company. Relief via onshore pooling will also be
available.

正确答案：A

正确答案：

(b) Accounting in the financial statements for the year ended 31 May 2005
IFRS2 requires an expense to be recognised for the share options granted to the directors with a corresponding amount shown
in equity. Where options do not vest immediately but only after a period of service, then there is a presumption that the
services will be rendered over the ‘vesting period’. The fair value of the services rendered will be measured by reference to
the fair value of the equity instruments at the date that the equity instruments were granted. Fair value should be based on
market prices. The treatment of vesting conditions depends on whether or not the conditions relate to the market price of the
instruments. Market conditions are effectively taken into account in determining the fair value of the instruments and therefore
can be ignored for the purposes of estimating the number of equity instruments that will vest. For other conditions such as
remaining in the employment of the company, the calculations are carried out based on the best estimate of the number of
instruments that will vest. The estimate is revised when subsequent information is available.
The share options granted to J. Van Heflin on 1 June 2002 were before the date set in IFRS2 for accounting for such options
(7 November 2002). Therefore, no expense calculation is required. (Note: candidates calculating the expense for the latter
share options would be given credit if they stated that the company could apply IFRS2 to other options in certaincircumstances.) The remaining options are valued as follows: