(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)

题目

(ii) Advise Andrew of the tax implications arising from the disposal of the 7% Government Stock, clearly

identifying the tax year in which any liability will arise and how it will be paid. (3 marks)

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第1题：

(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)

正确答案：

第2题：

of the potential capital gain, and explain any options available to Alan to reduce this tax liability. (7 marks)

正确答案：

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3题：

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)

正确答案：

(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4题：

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)

正确答案：

第5题：

(b) Mabel has two objectives when making the gifts to Bruce and Padma:

(1) To pay no tax on any gift in her lifetime; and

(2) To reduce the eventual liability to inheritance tax on her death.

Advise Mabel which item to gift to Bruce and to Padma in order to satisfy her objectives. Give reasons for

your advice.

Your advice should include a computation of the inheritance tax saved as a result of the two gifts, on the

assumption that Mabel dies on 30 June 2011. (10 marks)

正确答案：

第6题：

(d) Advise on any lifetime inheritance tax (IHT) planning that could be undertaken in respect of both Stuart and

Rebecca to help reduce the potential inheritance tax (IHT) liability calculated in (c) above. (7 marks)

Relevant retail price index figures are:

May 1994 144·7

April 1998 162·6

正确答案：
(d) Stuart is not making use of his nil rate band, as all assets are transferred, exempt from inheritance tax (IHT), to Rebecca (as
spouse) on death. He should consider altering his will to transfer an amount equivalent to the nil rate band to his son, Sam.
If Stuart dies before altering his will, Rebecca can elect to make a Deed of Variation in favour of Sam instead. This will have
the same effect as the above.
Care should be taken in determining which assets are subject to this legacy. The Omega plc shares should not be transferred
to Sam as they currently attract 50% BPR. Instead, assets not subject to any reliefs (such as the insurance payout or cash
deposits) should be used instead. By doing this, IHT of ￡105,200 (￡263,000 x 40%) could be saved on the ultimate death
of Rebecca.
It is too late for Stuart to make use of potentially exempt transfers (PETs) as no relief is obtained until three years have passed,
and full relief only occurs seven years after making the gifts. The same would also apply to Rebecca if she were to die on 1
March 2008. However, as she is currently in good health, she may decide to make lifetime gifts, although she should also
not gift the Omega plc shares for the reasons stated above as any gift other than of the entire holding will result in the loss
of BPR on the remainder.
Both individuals should make use of their annual exemptions (￡3,000 per person per year). The annual exemptions not used
up in the previous year can be used in this current year. This would give a saving of ￡2,400 each (3,000 x 2 x 40%).
Exemptions for items such as small gifts (￡250 per donee per year) are also available.
Gifts out of normal income should also be considered. After making such gifts, the individual should be left with sufficient
income to maintain their usual standard of living. To obtain the exemption, it is usually necessary to demonstrate general
evidence of a prior commitment to make the gifts, or a settled pattern of expenditure.
While there are no details of income, both Stuart and Rebecca are wealthy in their own right, and are likely to earn reasonable
sums from their investments. They should therefore be able to satisfy the conditions on that basis.
If Rebecca were to make substantial lifetime gifts, the donees would be advised to consider taking out insurance policies on
Rebecca’s life to cover the potential tax liabilities that may arise on any PETs in the event of her early death.
Tutorial note: the answer has assumed that the shares could be bought for ￡2·10, their value for IHT.

第7题：

(ii) Explain the income tax (IT), national insurance (NIC) and capital gains tax (CGT) implications arising on

the grant to and exercise by an employee of an option to buy shares in an unapproved share option

scheme and on the subsequent sale of these shares. State clearly how these would apply in Henry’s

case. (8 marks)

正确答案：
(ii) Exercising of share options
The share option is not part of an approved scheme, and will not therefore enjoy the benefits of such a scheme. There
are three events with tax consequences – grant, exercise and sale.
Grant. If shares or options over shares are sold or granted at less than market value, an income tax charge can arise on
the difference between the price paid and the market value. [Weight v Salmon]. In addition, if options can be exercised
more than 10 years after the date of the grant, an employment income charge can arise. This is based on the market
value at the date of grant less the grant and exercise priced.
In Henry’s case, the options were issued with an exercise price equal to the then market value, and cannot be exercised
more than 10 years from the grant. No income tax charge therefore arises on grant.
Exercise. On exercise, the individual pays the agreed amount in return for a number of shares in the company. The price
paid is compared with the open market value at that time, and if less, the difference is charged to income tax. National
insurance also applies, and the company has to pay Class 1 NIC. If the company and shareholder agree, the national
insurance can be passed onto the individual, and the liability becomes a deductible expense in calculating the income
tax charge.
In Henry’s case on exercise, the difference between market value (￡14) and the price paid (￡1) per share will be taxed
as income. Therefore, ￡130,000 (10,000 x (￡14 – ￡1)) will be taxed as income. In addition, national insurance will
be chargeable on the company at 12·8% (￡16,640) and on Henry at the rate of 1% (￡1,300).
Sale. The base cost of the shares is taken to be the market value at the time of exercise. On the sale of the shares, any
gain or loss arising falls under the capital gains tax rules, and CGT will be payable on any gain. Business asset taper
relief will be available as the company is an unquoted trading company, but the relief will only run from the time that
the share options are exercised – i.e. from the time when the shares were acquired.
In Henry’s case, the sale of the shares will immediately follow the exercise of the option (6 days later). The sale proceeds
and the market value at the time of exercise are likely to be similar; thus little to no gain is likely to arise.

第8题：

of a remuneration expense for the directors’ share options. (7 marks)

正确答案：

第9题：

could 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 the

foreseeable future.

正确答案：
(c) Further advice
Mabel should consider delaying one of the gifts until after 1 May 2007 such that it is made more than seven years after the
gift to the discretionary trust. Both PETs would then be covered by the nil rate band resulting in a saving of inheritance tax
of ￡6,720 (from (b)).
Mabel should ensure that she uses her inheritance tax annual exemption of ￡3,000 every year by, say, making gifts of ￡1,500
each year to both Bruce and Padma. The effect of this will be to save inheritance tax of ￡1,200 (￡3,000 x 40%) every year.

第10题：

reduce the liability. (3 marks)

正确答案：

(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)

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