(c) (i) Compute Gloria’s capital gains tax liability for 2006/07 ignoring any claims or elections available to
reduce the liability. (3 marks)
第1题：
(b) Explain the capital gains tax (CGT) and inheritance tax (IHT) implications of Graeme gifting his remaining ‘T’
ordinary shares at their current value either:
(i) to his wife, Catherine; or
(ii) to his son, Barry.
Your answer should be supported by relevant calculations and clearly identify the availability and effect of
any reliefs (other than the CGT annual exemption) that might be used to reduce or defer any tax liabilities
arising. (9 marks)
第2题：
(ii) State, giving reasons, the tax reliefs in relation to inheritance tax (IHT) and capital gains tax (CGT) which
would be available to Alasdair if he acquires the warehouse and leases it to Gallus & Co, rather than to
an unconnected tenant. (4 marks)
第3题：
(b) Assuming that Thai Curry Ltd claims relief for its trading loss against total profits under s.393A ICTA 1988,calculate the company’s corporation tax liability for the year ended 30 September 2005. (10 marks)
第4题：
(c) Calculate the expected corporation tax liability of Dovedale Ltd for the year ending 31 March 2007 on the
assumption that all available reliefs are claimed by Dovedale Ltd but that Hira Ltd will not claim any capital
allowances in that year. (4 marks)
第5题：
(b) Assuming that the income from the sale of the books is not treated as trading income, calculate Bob’s taxable
income and gains for all relevant tax years, using any loss reliefs in the most tax-efficient manner. Your
answer should include an explanation of the loss reliefs available and your reasons for using (or not using)
them. (12 marks)
Assume that the rates and allowances for 2004/05 apply throughout this part of the question.
第6题：
(c) Assuming that Joanne registers for value added tax (VAT) with effect from 1 April 2006:
(i) Calculate her income tax (IT) and capital gains tax (CGT) payable for the year of assessment 2005/06.
You are not required to calculate any national insurance liabilities in this sub-part. (6 marks)
第7题：
(c) (i) Explain the capital gains tax (CGT) implications of a takeover where the consideration is in the form. of
shares (a ‘paper for paper’ transaction) stating any conditions that need to be satisfied. (4 marks)
第8题：
(c) (i) State the date by which Thai Curry Ltd’s self-assessment corporation tax return for the year ended
30 September 2005 should be submitted, and advise the company of the penalties that will be due if
the 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 2005
should be paid, and advise the company of the interest that will be due if the liability is not paid until
31 May 2007. (3 marks)
(c) Self-assessment tax return
(1) Thai Curry Ltd’s self-assessment corporation tax return for the year ended 30 September 2005 must be submitted by
30 September 2006.
(2) If the company does not submit its self-assessment tax return until 31 May 2007, then there will be an automatic fixed
penalty of ￡200 since the return is more than three months late.
(3) There will also be an additional corporation tax related penalty of ￡4,415 (44,150 × 10%) being 10% of the tax unpaid,
since the self-assessment tax return is more than six months late.
Corporation tax liability
(1) Thai Curry Ltd’s corporation tax liability for the year ended 30 September 2005 must be paid by 1 July 2006.
(2) If the company does not pay its corporation tax until 31 May 2007, then interest of ￡3,035 (44,150 at 7·5% = 3,311
× 11/12) will be charged by HM Revenue & Customs for the period 1 July 2006 to 31 May 2007.
第9题：
(c) Advise Alan on the proposed disposal of the shares in Mobile Ltd. Your answer should include calculations
of the potential capital gain, and explain any options available to Alan to reduce this tax liability. (7 marks)
However, an exemption from corporation tax exists for any gain arising when a trading company (or member of a trading
group) sells the whole or any part of a substantial shareholding in another trading company.
A substantial shareholding is one where the investing company holds 10% of the ordinary share capital and is beneficially
entitled to at least 10% of the
(i) profits available for distribution to equity holders and
(ii) assets of the company available for distribution to equity holders on a winding up.
In meeting the 10% test, shares owned by a chargeable gains group may be amalgamated. The 10% test must have been
met for a continuous 12 month period during the 2 years preceding the disposal.
The companies making the disposals must have been trading companies (or members of a trading group) throughout the
12 month period, as well as at the date of disposal. In addition, they must also be trading companies (or members of a trading
group) immediately after the disposal.
The exemption is given automatically, and acts to deny losses as well as eliminate gains.
While Alantech Ltd has owned its holding in Mobile Ltd for 33 months, its ownership of the Boron holding has only lasted
for 10 months (at 1 June 2005) since Boron was acquired on 1 July 2004. Selling the shares in June 2005 will fail the
12 month test, and the gain will become chargeable.
It would be better for the companies to wait for a further month until July 2005 before selling the amalgamated shareholding.
By doing so, they will both be able to take advantage of the substantial shareholdings relief, thereby saving tax of ￡29,625
assuming a corporation tax rate of 19%.
第10题：
(ii) Compute the annual income tax saving from your recommendation in (i) above as compared with the
situation where Cindy retains both the property and the shares. Identify any other tax implications
arising from your recommendation. Your answer should consider all relevant taxes. (3 marks)
