(c) (i) Explain how Messier Ltd can assist Galileo with the cost of relocating to the UK and/or provide him withinterest-free loan finance for this purpose without increasing his UK income tax liability; (3 marks)
(c) (i) Explain how Messier Ltd can assist Galileo with the cost of relocating to the UK and/or provide him with
interest-free loan finance for this purpose without increasing his UK income tax liability; (3 marks)
相关考题：
(c) (i) State the date by which Thai Curry Ltd’s self-assessment corporation tax return for the year ended30 September 2005 should be submitted, and advise the company of the penalties that will be due ifthe return is not submitted until 31 May 2007. (3 marks)(ii) State the date by which Thai Curry Ltd’s corporation tax liability for the year ended 30 September 2005should be paid, and advise the company of the interest that will be due if the liability is not paid until31 May 2007. (3 marks)
(c) Advise Alan on the proposed disposal of the shares in Mobile Ltd. Your answer should include calculationsof the potential capital gain, and explain any options available to Alan to reduce this tax liability. (7 marks)
(ii) Briefly outline the tax consequences for Henry if the types of protection identified in (i) were to beprovided for him by Happy Home Ltd compared to providing them for himself. You are not required todiscuss the corporation tax (CT) consequences for Happy Home Ltd. (4 marks)
(c) Without changing the advice you have given in (b), or varying the terms of Luke’s will, explain how Mabelcould further reduce her eventual inheritance tax liability and quantify the tax saving that could be made.(3 marks)The increase in the retail prices index from April 1984 to April 1998 is 84%.You should assume that the rates and allowances for the tax year 2005/06 will continue to apply for theforeseeable future.
(d) Explain whether or not Dovedale Ltd, Hira Ltd and Atapo Inc can register as a group for the purposes of valueadded tax. (3 marks)
(c) Outline the ways in which Arthur and Cindy can reduce their income tax liability by investing in unquotedshares and recommend, with reasons, which form. of investment best suits their circumstances. You are notrequired to discuss the qualifying conditions applicable to the investment vehicle recommended. (5 marks)You should assume that the income tax rates and allowances for the tax year 2005/06 apply throughout thisquestion
(d) Explain how Gloria would be taxed in the UK on the dividends paid by Bubble Inc and the capital gains taxand inheritance tax implications of a future disposal of the shares. Clearly state, giving reasons, whether ornot the payment made to Eric is allowable for capital gains tax purposes. (9 marks)You should assume that the rates and allowances for the tax year 2005/06 apply throughout this question.
(b) (i) Compute the corporation tax liability of Speak Write Ltd for its first trading period on the assumptionthat the IR 35 legislation applies to all of its income. (2 marks)
(ii) Assuming the relief in (i) is available, advise Sharon on the maximum amount of cash she could receiveon incorporation, without triggering a capital gains tax (CGT) liability. (3 marks)
(b) Peter, one of Linden Limited’s non-executive directors, having lived and worked in the UK for most of his adultlife, sold his home near London on 22 March 2006 and, together with his wife (a French citizen), moved to livein a villa which she owns in the south of France. Peter is now demanding that the tax deducted from his director’sfees, for the board meetings held on 18 April and 16 May 2006, be refunded, on the grounds that, as he is nolonger resident in the UK, he is no longer liable to UK income tax. All of the company’s board meetings are heldat its offices in Cambridge.Despite Peter’s assurance that none of the other companies of which he is a director has disputed his change oftax status, Damian is uncertain whether he should make the refunds requested. However, as Peter is a friend ofthe company’s founder, Linden Limited’s managing director is urging him to do so, stating that if the tax doeshave to be paid, then Linden Limited could always bear the cost.Required:Advise Damian whether Peter is correct in his assertion regarding his tax position and in the case that thereis a UK tax liability the implications of the managing director’s suggestion. You are not required to considernational insurance (NIC) issues. (4 marks)
(iii) Explain the potential corporation tax (CT) implications of Tay Limited transferring work to Trent Limited,and suggest how these can be minimised or eliminated. (3 marks)
(ii) Advise Andrew of the tax implications arising from the disposal of the 7% Government Stock, clearlyidentifying the tax year in which any liability will arise and how it will be paid. (3 marks)
(ii) Analyse the effect of delaying the sale of the business of the Stiletto Partnership to Razor Ltd until30 April 2007 on Clint’s income tax and national insurance position.You are not required to prepare detailed calculations of his income tax or national insurance liabilities.(4 marks)
(ii) The UK value added tax (VAT) implications for Razor Ltd of selling tools to and purchasing tools fromCutlass Inc; (2 marks)
(iii) The extent to which Amy will be subject to income tax in the UK on her earnings in respect of dutiesperformed for Cutlass Inc and the travel costs paid for by that company. (5 marks)Appropriateness of format and presentation of the report and the effectiveness with which its advice iscommunicated. (2 marks)Note:You should assume that the income tax rates and allowances for the tax year 2006/07 and the corporation taxrates and allowances for the financial year 2006 apply throughout this questio
(b) Explain the corporation tax and value added tax (VAT) implications of the following aspects of the proposedrestructuring of the Rapier Ltd group.(i) The immediate tax implications of the restructuring. (6 marks)
(ii) A proposal which will increase the after tax proceeds from the sale of the Snapper plc loan stock and areasoned recommendation of a more appropriate form. of external finance. (3 marks)
4 Coral is the owner and managing director of Reef Ltd. She is considering the manner in which she will make her firstpension 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 pensioncontributions 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 minimisethe 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 pensioncontributions 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)
(b) (i) Explain, by reference to Coral’s residence, ordinary residence and domicile position, how the rentalincome arising in respect of the property in the country of Kalania will be taxed in the UK in the tax year2007/08. State the strategy that Coral should adopt in order to minimise the total income tax sufferedon the rental income. (7 marks)
(ii) Explain how the inclusion of rental income in Coral’s UK income tax computation could affect theincome tax due on her dividend income. (2 marks)You are not required to prepare calculations for part (b) of this question.Note: you should assume that the tax rates and allowances for the tax year 2006/07 and for the financial year to31 March 2007 will continue to apply for the foreseeable future.
3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans toexpand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell hershares back to the company. Once the purchase of her shares has taken place, the company intends to establish anumber of branches overseas and acquire a shareholding in a number of companies that are resident and trade inoverseas 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 bebetween 23% and 42%.– There may or may not be a double tax treaty between the UK and the overseas countries in which the companiesare 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 companieswill 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 willreceive for her shares; (7 marks)
(b) Provide the directors of Acrux Ltd with a detailed explanation of the maximum rate of tax that will be sufferedon both the distributed and non-distributed profits of the non-UK resident investee companies where:(1) there is a double tax treaty between the UK and the country in which the individual companies areresident; and(2) there is no such double tax treaty.Note: you are not required to explain the position of the overseas resident branches. (6 marks)
(ii) Explain why Galileo is able to pay the inheritance tax due in instalments, state when the instalments aredue and identify any further issues relevant to Galileo relating to the payments. (3 marks)
(b) Prepare a reasoned explanation of how any capital gains tax arising in the UK on the sale of the paintingscan be minimised. (2 marks)
(ii) State, with reasons, whether Messier Ltd can provide Galileo with accommodation in the UK withoutgiving rise to a UK income tax liability. (2 marks)
2 Assume that today’s date is 1 July 2005.Jan is aged 45 and single. He is of Danish domicile but has been working in the United Kingdom since 1 May 2004and intends to remain in the UK for the medium to long term. Although Jan worked briefly in the UK in 1986, hehas forgotten how UK taxation works and needs some assistance before preparing his UK income tax return.Jan’s salary from 1 May 2004 was ￡74,760 per annum. Jan also has a company car – a Jaguar XJ8 with a list priceof ￡42,550 including extras, and CO2 emissions of 242g/km. The car was available to him from 1 July 2004. Freepetrol is provided by the company. Jan has other taxable benefits amounting to ￡3,965.Jan’s other 2004/05 income comprises:￡Dividend income from UK companies (cash received) 3,240Interest received on an ISA account 230Interest received on a UK bank account 740Interest remitted from an offshore account (net of 15% withholding tax) 5,100Income remitted from a villa in Portugal (net of 45% withholding tax) 4,598The total interest arising on the offshore account was ￡9,000 (gross). In addition, Jan has not remitted otherPortuguese rental income arising in the year, totalling a further ￡1,500 (gross).Jan informs you that his employer is thinking of providing him with rented accommodation while he looks for a houseto buy. The accommodation would be a two bedroom flat, valued at ￡155,000 with an annual value of ￡6,000. Itwould be made available from 6 August 2005. The company will pay the rent of ￡600 per month for the first sixmonths. All other bills will be paid by Jan.Jan also informs you that he has 25,000 ordinary shares in Gilet Ltd (‘Gilet’), an unquoted UK trading company. Hehas held these shares since August 1986 when he bought 2,500 shares at ￡4.07 per share. In January 1994, abonus issue gave each shareholder nine shares for each ordinary share held. In the last week all Gilet’s shareholdershave received an offer from Jumper plc (‘Jumper’) who wishes to acquire the shares. Jumper has offered the following:– 3 shares in Jumper (currently trading at ￡3.55 per share) for every 5 shares in Gilet, and– 25p cash per shareRequired:(a) Calculate Jan’s 2004/05 income tax (IT) payable. (11 marks)