A Club member pays ￡2.5 for a year’s membership.

(ii) Assuming that Donald operates through a company, advise Donald on the corporation tax (CT) that

would be payable for the year ended 31 March 2007 if he pays himself a gross salary of ￡31,000, plus

a net dividend of ￡10,000, instead of a gross salary of ￡42,648. (4 marks)

3 On 1 January 2007 Dovedale Ltd, a company with no subsidiaries, intends to purchase 65% of the ordinary share

capital of Hira Ltd from Belgrove Ltd. Belgrove Ltd currently owns 100% of the share capital of Hira Ltd and has no

other subsidiaries. All three companies have their head offices in the UK and are UK resident.

Hira Ltd had trading losses brought forward, as at 1 April 2006, of ￡18,600 and no income or gains against which

to offset losses in the year ended 31 March 2006. In the year ending 31 March 2007 the company expects to make

further tax adjusted trading losses of ￡55,000 before deduction of capital allowances, and to have no other income

or gains. The tax written down value of Hira Ltd’s plant and machinery as at 31 March 2006 was ￡96,000 and

there will be no fixed asset additions or disposals in the year ending 31 March 2007. In the year ending 31 March

2008 a small tax adjusted trading loss is anticipated. Hira Ltd will surrender the maximum possible trading losses

to Belgrove Ltd and Dovedale Ltd.

The tax adjusted trading profit of Dovedale Ltd for the year ending 31 March 2007 is expected to be ￡875,000 and

to continue at this level in the future. The profits chargeable to corporation tax of Belgrove Ltd are expected to be

￡38,000 for the year ending 31 March 2007 and to increase in the future.

On 1 February 2007 Dovedale Ltd will sell a small office building to Hira Ltd for its market value of ￡234,000.

Dovedale Ltd purchased the building in March 2005 for ￡210,000. In October 2004 Dovedale Ltd sold a factory

for ￡277,450 making a capital gain of ￡84,217. A claim was made to roll over the gain on the sale of the factory

against the acquisition cost of the office building.

On 1 April 2007 Dovedale Ltd intends to acquire the whole of the ordinary share capital of Atapo Inc, an unquoted

company resident in the country of Morovia. Atapo Inc sells components to Dovedale Ltd as well as to other

companies in Morovia and around the world.

It is estimated that Atapo Inc will make a profit before tax of ￡160,000 in the year ending 31 March 2008 and will

pay a dividend to Dovedale Ltd of ￡105,000. It can be assumed that Atapo Inc’s taxable profits are equal to its profit

before tax. The rate of corporation tax in Morovia is 9%. There is a withholding tax of 3% on dividends paid to

non-Morovian resident shareholders. There is no double tax agreement between the UK and Morovia.

Required:

(a) Advise Belgrove Ltd of any capital gains that may arise as a result of the sale of the shares in Hira Ltd. You

are not required to calculate any capital gains in this part of the question. (4 marks)

A.have,,joined

B.have,,been

C.has,,joined

D.has,,been

3 The Stiletto Partnership consisted of three partners, Clint, Ben and Amy, who shared the profits of the business

equally. On 28 February 2007 the partners sold the business to Razor Ltd, in exchange for shares in Razor Ltd, with

each former partner owning one third of the new company.

The recent, tax adjusted, trading profits of the Stiletto Partnership have been as follows:

￡

Year ended 30 June 2006 92,124

1 July 2006 to 28 February 2007 81,795

Clint, who was 65 on 5 October 2006, retired when the business was sold to Razor Ltd. He is now suggesting that

if the sale of the partnership, and his retirement, had been delayed until 30 April 2007, his total tax liability would

have been reduced. Clint’s only other income is gross pension income of ￡6,100 per year, which he began receiving

in the tax year 2005/06. Clint did not receive any salary or dividends from Razor Ltd. It is estimated that the

partnership’s tax adjusted trading profits for the period from 1 March 2007 to 30 April 2007 would have been

￡20,760. Clint has overlap profits of ￡14,250 brought forward from when the partnership began trading.

Razor Ltd manufactures industrial cutting tools. On 1 July 2007, Razor Ltd will subscribe for the whole of the ordinary

share capital of Cutlass Inc, a company newly incorporated in the country of Sharpenia. It is intended that Cutlass

Inc will purchase partly finished tools from Razor Ltd and customise them in Sharpenia. It is anticipated that Cutlass

Inc’s annual profits chargeable to corporation tax will be approximately ￡120,000.

Ben and Amy will be the directors of Cutlass Inc, although Ben will not be involved in the company’s business on a

day-to-day basis. Amy intends to spend one or two weeks each month in the country of Sharpenia looking after the

company’s affairs. The remainder of her time will be spent in the UK. Amy has employment contracts with both Razor

Ltd and Cutlass Inc and her duties for Cutlass Inc will be carried out wholly in Sharpenia. Cutlass Inc will pay for

Amy’s flights to and from Sharpenia and for her husband and baby to visit her there twice a year. Amy is currently

UK resident and ordinarily resident.

The system of income tax and corporation tax in the country of Sharpenia is broadly similar to that in the UK although

the rate of corporation tax is 38% regardless of the level of profits. There is a double tax treaty between the UK and

Sharpenia based on the OECD model treaty. The clause in the treaty dealing with company residency states that a

company resident in both countries under domestic law will be regarded under the treaty as being resident only in the

country where it is effectively managed and controlled. Sharpenia is not a member of the European Union.

Required:

(a) (i) Calculate Clint’s taxable trading profits for the tax years 2006/07 and 2007/08 for both of the

alternative retirement dates (28 February 2007 and 30 April 2007). (3 marks)

2 Clifford and Amanda, currently aged 54 and 45 respectively, were married on 1 February 1998. Clifford is a higher

rate taxpayer who has realised taxable capital gains in 2007/08 in excess of his capital gains tax annual exemption.

Clifford moved into Amanda’s house in London on the day they were married. Clifford’s own house in Oxford, where

he had lived since acquiring it for ￡129,400 on 1 August 1996, has been empty since that date although he and

Amanda have used it when visiting friends. Clifford has been offered ￡284,950 for the Oxford house and has decided

that it is time to sell it. The house has a large garden such that Clifford is also considering an offer for the house and

a part only of the garden. He would then sell the remainder of the garden at a later date as a building plot. His total

sales proceeds will be higher if he sells the property in this way.

Amanda received the following income from quoted investments in 2006/07:

￡

Dividends in respect of quoted trading company shares 1,395

Dividends paid by a Real Estate Investment Trust out of tax exempt property income 485

On 1 May 2006, Amanda was granted a 22 year lease of a commercial investment property. She paid the landlord

a premium of ￡6,900 and also pays rent of ￡2,100 per month. On 1 June 2006 Amanda granted a nine year

sub-lease of the property. She received a premium of ￡14,700 and receives rent of ￡2,100 per month.

On 1 September 2006 Amanda gave quoted shares with a value of ￡2,200 to a registered charity. She paid broker’s

fees of ￡115 in respect of the gift.

Amanda began working for Shearer plc, a quoted company, on 1 June 2006 having had a two year break from her

career. She earns an annual salary of ￡38,600 and was paid a bonus of ￡5,750 in August 2006 for agreeing to

come and work for the company. On 1 August 2006 Amanda was provided with a fully expensed company car,

including the provision of private petrol, which had a list price when new of ￡23,400 and a CO2 emissions rate of

187 grams per kilometre. Amanda is required to pay Shearer plc ￡22 per month in respect of the private use of the

car. In June and July 2006 Amanda used her own car whilst on company business. She drove 720 business miles

during this two month period and was paid 34 pence per mile. Amanda had PAYE of ￡6,785 deducted from her gross

salary in the tax year 2006/07.

After working for Shearer plc for a full year, Amanda becomes entitled to the following additional benefits:

– The opportunity to purchase a large number of shares in Shearer plc on 1 July 2007 for ￡3·30 per share. It is

anticipated that the share price on that day will be at least ￡7·50 per share. The company will make an interestfree

loan to Amanda equal to the cost of the shares to be repaid in two years.

– Exclusive free use of the company sailing boat for one week in August 2007. The sailing boat was purchased by

Shearer plc in January 2005 for use by its senior employees and costs the company ￡1,400 a week in respect

of its crew and other running expenses.

Required:

(a) (i) Calculate Clifford’s capital gains tax liability for the tax year 2007/08 on the assumption that the Oxford

house together with its entire garden is sold on 31 July 2007 for ￡284,950. Comment on the relevance

to your calculations of the size of the garden; (5 marks)

(b) Donald actually decided to operate as a sole trader. The first year’s results of his business were not as he had

hoped, and he made a trading loss of ￡8,000 in the year to 31 March 2007. However, trading is now improving,

and Donald has sufficient orders to ensure that the business will make profits of at least ￡30,000 in the year to

31 March 2008.

In order to raise funds to support his business over the last 15 months, Donald has sold a painting which was

given to him on the death of his grandmother in January 1998. The probate value of the painting was ￡3,200,

and Donald sold it for ￡8,084 (after deduction of 6% commission costs) in November 2006.

He also sold other assets in the year of assessment 2006/07, realising further chargeable gains of ￡8,775 (after

indexation of ￡249 and taper relief of ￡975).

Required:

(i) Calculate the chargeable gain on the disposal of the painting in November 2006. (4 marks)

6 Andrew is aged 38 and is single. He is employed as a consultant by Bestadvice & Co and pays income tax at the

higher rate.

Andrew is considering investing in a new business, and to provide funds for this investment he has recently disposed

of the following assets:

(1) A short leasehold interest in a residential property. Andrew originally paid ￡50,000 for a 47 year lease of the

property in May 1995, and assigned the lease in May 2006 for ￡90,000.

(2) His holding of ￡10,000 7% Government Stock, on which interest is payable half-yearly on 20 April and

20 October. Andrew originally purchased this holding on 1 June 1999 for ￡9,980 and he sold it for ￡11,250

on 14 March 2005.

Andrew intends to subscribe for ordinary shares in a new company, Scalar Limited, which will be a UK based

manufacturing company. Three investors (including Andrew) have been identified, but a fourth investor may also be

invited to subscribe for shares. The investors are all unconnected, and would subscribe for shares in equal measure.

The intention is to raise ￡450,000 in this manner. The company will also raise a further ￡50,000 from the investors

in the form. of loans. Andrew has been told that he can take advantage of some tax reliefs on his investment in Scalar

Limited, but does not know anything about the details of these reliefs

Andrew’s employer, Bestadvice & Co, is proposing to change the staff pension scheme from a defined benefit scheme

to which the firm and the employees each contribute 6% of their annual salary, to a defined contribution scheme, to

which the employees will continue to contribute 6%, but the firm will contribute 8% of their annual salary. The

majority of Andrew’s colleagues are opposed to this move, but, given the increase in the firm’s contribution rate

Andrew himself is less sure that the proposal is without merit.

Required:

(a) (i) Calculate the chargeable gain arising on the assignment of the residential property lease in May 2006.

(2 marks)

3 Seejoy is a famous football club but has significant cash flow problems. The directors and shareholders wish to take

steps to improve the club’s financial position. The following proposals had been drafted in an attempt to improve the

cash flow of the club. However, the directors need advice upon their implications.

(a) Sale and leaseback of football stadium (excluding the land element)

The football stadium is currently accounted for using the cost model in IAS16, ‘Property, Plant, and Equipment’.

The carrying value of the stadium will be $12 million at 31 December 2006. The stadium will have a remaining

life of 20 years at 31 December 2006, and the club uses straight line depreciation. It is proposed to sell the

stadium to a third party institution on 1 January 2007 and lease it back under a 20 year finance lease. The sale

price and fair value are $15 million which is the present value of the minimum lease payments. The agreement

transfers the title of the stadium back to the football club at the end of the lease at nil cost. The rental is

$1·2 million per annum in advance commencing on 1 January 2007. The directors do not wish to treat this

transaction as the raising of a secured loan. The implicit interest rate on the finance in the lease is 5·6%.

(9 marks)

Required:

Discuss how the above proposals would be dealt with in the financial statements of Seejoy for the year ending

31 December 2007, setting out their accounting treatment and appropriateness in helping the football club’s

cash flow problems.

(Candidates do not need knowledge of the football finance sector to answer this question.)

6 Sergio and Gerard each inherited a half interest in a property, ‘Hilltop’, in October 2005. ‘Hilltop’ had a probate value

of ￡124,000, but in November 2005 it was badly damaged by fire. In January 2006 the insurance company made

a payment of ￡81,700 each to Sergio and Gerard. In February 2006 Sergio and Gerard each spent ￡55,500 of the

insurance proceeds on restoring the property. ‘Hilltop’ was worth ￡269,000 following the restoration work. In July

2006, Sergio and Gerard sold ‘Hilltop’ for ￡310,000.

Sergio is 69 years old and a widower with three adult children and seven grandchildren. His annual income consists

of a pension of ￡9,900 and interest of ￡300 on savings of ￡7,600 in a bank deposit account. Sergio owns his home

but no other significant assets. He plans to buy a domestic rental property with the proceeds from the sale of ‘Hilltop’,

such that on his death he will have a significant asset which can be sold and divided between the members of his

family.

Gerard is 34 years old. He is employed by Fizz plc on a salary of ￡66,500 per year together with a performance

related bonus. Gerard estimates that he will receive a bonus in December 2007 of ￡4,500, in line with previous

years, and that his taxable benefits in the tax year 2007/08 will amount to ￡7,140. He also expects to receive

dividends from UK companies of ￡1,935 and bank interest of ￡648 in the tax year 2007/08. Gerard intends to set

up a personal pension plan in August 2007. He has not made any pension contributions in the past and proposes to

use part of the proceeds from the sale of ‘Hilltop’ to make the maximum possible tax allowable contribution.

Fizz plc has announced that it intends to replace the performance related bonus scheme with a share incentive plan,

also linked to performance, with effect from 6 April 2008. Gerard estimates that Fizz plc will award him free shares

worth ￡2,100 each year. He will also purchase partnership shares worth ￡700 each year and, as a result, will be

awarded matching shares (further free shares) worth ￡1,400.

Required:

(a) Calculate the chargeable gains arising on the receipt of the insurance proceeds in January 2006 and the sale

of ‘Hilltop’ in July 2006. You should assume that any elections necessary to minimise the gain on the receipt

of the insurance proceeds have been submitted. (4 marks)

I have four good f(41) ．They're Jennifer， Victor， Cindy and Leila． We are in the same(相同的) c(42) ．Jennifer swims very w(43) ．She wants to join the s(44) club． Then she can swim on S(45) 0r Sundays． Victor wants to join the art club because he is good at p(46) ．Cindy is a pop music fan． She can s(47) a lot of songs． So she wants to join the s(48) club． Leila wants to join the music club be-cause she p(49) the violin very well． And she wants to be a m(50) when she

grows up(长大)．1 like them very much．

41．_________