(iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of inserting Bold plc as
a holding company and identify any planning actions that can be taken to defer or minimise these tax
costs. (4 marks)
You should assume that the corporation tax rates for the financial year 2005 and the income tax rates
and allowances for the tax year 2005/06 apply throughout this question.
第1题:
Assume that the corporation tax rates for the financial year 2004 apply throughout.
(b) Explain the corporation tax (CT) and value added tax (VAT) issues that Irroy should be aware of, if she
proceeds with her proposal for the Irish subsidiary, Green Limited. Your answer should clearly identify those
factors which will determine whether or not Green Limited is considered UK resident or Irish resident and
the tax implications of each alternative situation.
You need not repeat points that are common to each situation. (16 marks)
第2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3题:
(c) Assuming that Stuart:
(i) purchased 201,000 shares in Omega plc on 3 December 2005; and
(ii) dies on 20 December 2007,
calculate the potential inheritance tax (IHT) liability which would arise if Rebecca were to die on 1 March
2008, and no further tax planning measures were taken.
Assume that all asset values remain unchanged and that the current rates of inheritance tax continue to
apply. (6 marks)
第4题:
(c) Explain the capital gains tax (CGT) and income tax (IT) issues Paul and Sharon should consider in deciding
which form. of trust to set up for Gisella and Gavin. You are not required to consider inheritance tax (IHT) or
stamp duty land tax (SDLT) issues. (10 marks)
You should assume that the tax rates and allowances for the tax year 2005/06 apply throughout this question.
第5题:
(ii) Explain, with reasons, the relief available in respect of the fall in value of the shares in All Over plc,
identify the years in which it can be claimed and state the time limit for submitting the claim.
(3 marks)
第6题:
(b) Write a letter to Joanne setting out the value added tax (VAT) registration requirements and advising on
whether or not she should or could register for VAT and if registered if she could recover the VAT suffered on
the consultancy fees and computer purchased in October 2005. (7 marks)
第7题:
(b) (i) Calculate the inheritance tax (IHT) that will be payable if Debbie were to die today (8 June 2005).
Assume that no tax planning measures are taken and that there has been no change in the value of any
of the assets since David’s death. (4 marks)
第8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9题:
(iii) State any disadvantages to the relief in (i) that Sharon should be aware of, and identify and describe
another relief that she might use. (4 marks)
第10题:
(c) For commercial reasons, Damian believes that it would be sensible to place a new holding company, Bold plc,
over the existing company, Linden Limited. Bold plc would also be unquoted and would acquire the existing
Linden Limited shares in exchange for the issue of its own shares.
If the new structure is implemented, Bold plc will provide management services to Linden Limited, but the
amount that will be charged for these services is yet to be determined.
Required:
(i) State the capital gains tax (CGT) issues that Damian should be aware of before disposing of his shares
in Linden Limited to Bold plc. Your answer should include details of any conditions that will need to be
satisfied if an immediate charge to tax is to be avoided. (4 marks)