5 (a) Carver Ltd was incorporated and began tradin...

第1题

（ii) Explain whether or not Carver Ltd will become a close investment-holding company as a

(ii) Explain whether or not Carver Ltd will become a close investment-holding company as a result of

acquiring either the office building or the share portfolio and state the relevance of becoming such a

company. (2 marks)

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第2题

（b) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of t

(b) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of the new premises in the

year ending 31 March 2009 and explain, using illustrative calculations, how any additional recoverable input

tax will be calculated in future years. (5 marks)

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第3题

SHL Ltd, a property developer, developed a shopping mall. SHL Ltd acquired the land use ri

ght for RMB10 million and incurred construction costs of RMB12 million. The shopping mall was sold for RMB32 million.

What is the amount of business tax payable on the sale of the shopping mall？

A.RMB1·6 million

B.RMB1·1 million

C.RMB0·5 million

D.RMB1 million

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第4题

Required:（iii) A firm of consultants has offered to undertake a study on behalf of Envico

Required:

(iii) A firm of consultants has offered to undertake a study on behalf of Envico Ltd which will provide perfect

information regarding seminar attendance during the forthcoming year.

Advise the management of Envico Ltd with regard to the maximum amount that they should pay to

consultants for perfect information regarding seminar attendance and comment briefly on the use of

perfect information in such decisions. (5 marks)

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第5题

（b) A summary of the information needed to satisfy our obligations under the money launder

(b) A summary of the information needed to satisfy our obligations under the money laundering legislation and

any action that should be taken before agreeing to become tax advisers to the Saturn Ltd group. (5 marks)

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第6题

5 Gagarin wishes to persuade a number of wealthy individuals who are business contacts to

invest in his company,

Vostok Ltd. He also requires advice on the recoverability of input tax relating to the purchase of new premises.

The following information has been obtained from a meeting with Gagarin.

Vostok Ltd:

– An unquoted UK resident company.

– Gagarin owns 100% of the company’s ordinary share capital.

– Has 18 employees.

– Provides computer based services to commercial companies.

– Requires additional funds to finance its expansion.

Funds required by Vostok Ltd:

– Vostok Ltd needs to raise ￡420,000.

– Vostok Ltd will issue 20,000 shares at ￡21 per share on 31 August 2008.

– The new shareholder(s) will own 40% of the company.

– Part of the money raised will contribute towards the purchase of new premises for use by Vostok Ltd.

Gagarin’s initial thoughts:

– The minimum investment will be 5,000 shares and payment will be made in full on subscription.

– Gagarin has a number of wealthy business contacts who may be interested in investing.

– Gagarin has heard that it may be possible to obtain tax relief for up to 60% of the investment via the enterprise

investment scheme.

Wealthy business contacts:

– Are all UK resident higher rate taxpayers.

– May wish to borrow the funds to invest in Vostok Ltd if there is a tax incentive to do so.

New premises:

– Will cost ￡446,500 including value added tax (VAT).

– Will be used in connection with all aspects of Vostok Ltd’s business.

– Will be sold for ￡600,000 plus VAT in six years time.

– Vostok Ltd will waive the VAT exemption on the sale of the building.

The VAT position of Vostok Ltd:

– In the year ending 31 March 2009, 28% of Vostok Ltd’s supplies will be exempt for the purposes of VAT.

– This percentage is expected to reduce over the next few years.

– Irrecoverable input tax due to the company’s partially exempt status exceeds the de minimis limits.

Required:

(a) Prepare notes for Gagarin to use when speaking to potential investors. The notes should include:

(i) The tax incentives immediately available in respect of the amount invested in shares issued in

accordance with the enterprise investment scheme; (5 marks)

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第7题

Joe is the managing director and 100% shareholder of OK-Joe Ltd. He has always withdrawn t

he entire profits of the company as director’s remuneration, but given a recent increase in profitability he wants to know whether this basis of extracting the profits is beneficial.

For the year ended 5 April 2016, OK-Joe Ltd’s taxable total profits, before taking account of director’s remuneration, are ￡65,000. After allowing for employer’s class 1 national insurance contributions (NIC) of ￡5,141, Joe’s gross director’s remuneration is ￡59,859.

The figure for employer’s NIC of ￡5,141 is after deducting the ￡2,000 employment allowance.

Required:

Calculate the overall saving of tax and NIC for the year ended 5 April 2016 if Joe had instead paid himself gross director’s remuneration of ￡8,000 and net dividends of ￡45,600.

Notes:

1. You are expected to calculate the income tax payable by Joe, the class 1 NIC payable by both Joe and OK-Joe Ltd, and the corporation tax liability of OK-Joe Ltd for the year ended 5 April 2016. 2. You should assume that the rate of corporation tax remains unchanged.

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第8题

Your firm has been asked to provide advice to Granada Ltd, and one of its shareholders, Ma

ria. Maria wants advice on the tax consequences of selling some of her shares back to Granada Ltd. Granada Ltd wants advice on the corporation tax and value added tax (VAT) implications of the recent acquisition of an unincorporated business.

Maria:

– Is resident and domiciled in the UK.

– Is a higher rate taxpayer and will remain so in the future.

– Has already realised chargeable gains of ￡15,000 in the tax year 2015/16.

Shares in Granada Ltd:

– Maria subscribed for 10,000 ￡1 ordinary shares in Granada Ltd at par in June 2006.

– Maria is one of four equal shareholders and directors of Granada Ltd.

– Maria intends to sell either 2,700 or 3,200 shares back to the company on 31 March 2016 at their current market value of ￡12·80 per share.

– All of the conditions for capital treatment are satisfied, except for, potentially, the condition relating to the reduction in the level of shareholding.

Granada Ltd:

– Is a UK resident trading company which manufactures knitwear.

– Prepares accounts to 31 December each year.

– Is registered for VAT.

– Acquired the trade and assets of an unincorporated business, Starling Partners, on 1 January 2016.

Starling Partners:

– Had been trading as a partnership for many years as a wholesaler of handbags within the UK.

– Starling Partners’ main assets comprise a freehold commercial building and its ‘Starling’ brand, which were valued on acquisition by Granada Ltd at ￡105,000 and ￡40,000 respectively.

– Is registered for VAT.

– The transfer of its trade and assets to Granada Ltd qualified as a transfer of a going concern (TOGC) for VAT purposes.

– The business is forecast to make a trading loss of ￡130,000 in the year ended 31 December 2016.

Granada Ltd – results and proposed expansion:

– The knitwear business is expected to continue making a taxable trading profit of around ￡100,000 each year.

– Granada Ltd has no non-trading income but realised a chargeable gain of ￡10,000 on 1 March 2016.

– Granada Ltd is considering expanding the wholesale handbag trade acquired from Starling Partners into the export market from 1 January 2017.

– Granada Ltd anticipates that this expansion will result in the wholesale handbag trade returning a profit of ￡15,000 in the year ended 31 December 2017.

Required:

(a) (i) Explain, with the aid of calculations, why the capital treatment WILL NOT apply if Maria sells 2,700 of her shares back to Granada Ltd, but WILL apply if, alternatively, she sells back 3,200 shares. (4 marks)

(ii) Calculate Maria’s after-tax proceeds per share if she sells:

(1) 2,700 shares back to Granada Ltd; and alternatively

(2) 3,200 shares back to Granada Ltd. (4 marks)

(b) (i) Describe the corporation tax treatment of the acquisition of the ‘Starling’ brand by Granada Ltd, if no charge for amortisation was required in its statement of profit or loss. (3 marks)

(ii) Discuss how Granada Ltd could obtain relief for the trading loss expected to be incurred by the trade acquired from Starling Partners, if it does not wish to carry any of the loss back. (5 marks)

(c) Explain the value added tax (VAT) implications for Granada Ltd in respect of the acquisition of the business of Starling Partners, and the additional information needed in relation to the building to fully clarify the VAT position. (4 marks)

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第9题

（a) Mr Xu, a domestic Chinese, is a designer. He is considering the following four options

(a) Mr Xu, a domestic Chinese, is a designer. He is considering the following four options:

Option A: Joining Delta Ltd as a manager with a monthly salary of RMB40,000 and an annual bonus of RMB100,000 payable in December each year.

Option B: Providing services to Delta Ltd as a consultant for a consultancy fee of RMB50,000 per month.

Option C: Setting up his own sole proprietorship. He will pay himself a monthly salary of RMB20,000 from this sole proprietorship. For 2014 the net profit of the sole proprietorship after charging Mr Xu’s salary is expected to be RMB420,000.

Option D: Setting up a limited company, Xupa Ltd. He will pay himself a monthly salary of RMB20,000 from Xupa Ltd. For 2014 the net profit of the company after charging Mr Xu’s salary is expected to be RMB420,000. Xupa Ltd will pay enterprise income tax at the rate of 25% and distribute all of its profit after tax to its shareholder, Mr Xu, as a dividend.

Required:

Calculate the individual income tax (IIT) payable by Mr Xu for 2014 under each of the four options.

Note: Ignore value added tax and business tax. (10 marks)

(b) State, giving reasons, whether the following persons will be subject to individual income tax in China on their worldwide income in 2014:

(1) Ms Wang has her household in Xiamen and holds a China identity card. She has been studying in Australia since 2010 and has not returned to China for the last six years, including in 2014.

(2) Mr Beth is a US citizen, who has lived in China working for a non-government organisation since 2010. He has not travelled outside China for the last six years, including in 2014.

(3) Ms Ruth is an Australian citizen. She travelled to China and stayed in China for a total of 250 days in 2014. (5 marks)

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第10题

（d) Explain whether or not Dovedale Ltd, Hira Ltd and Atapo Inc can register as a group fo

(d) Explain whether or not Dovedale Ltd, Hira Ltd and Atapo Inc can register as a group for the purposes of value

added tax. (3 marks)

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5 （a) Carver Ltd was incorporated and began trading in August 2002. It is a close company