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[主观题]

Alpha Trading Ltd （Alpha) is a value added tax （VAT) general taxpayer. On 1 January 2014,

Alpha Trading Ltd (Alpha) is a value added tax (VAT) general taxpayer. On 1 January 2014, Alpha lent RMB200,000 to Beta Ltd at an interest rate of 10% per annum.

What is the type and amount of turnover tax which Alpha Trading Ltd will pay on the interest income received for the year 2014？

A.Business tax of RMB1,053

B.Business tax of RMB1,000

C.Value added tax of RMB3,400

D.Value added tax of RMB1,200

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更多“Alpha Trading Ltd （Alpha) is a…”相关的问题

第1题

（ii) The use of the trading loss of Tethys Ltd for the year ending 31 December 2008; （6 ma

(ii) The use of the trading loss of Tethys Ltd for the year ending 31 December 2008; (6 marks)

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第2题

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)

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第3题

Your firm has been asked to provide advice to Granada Ltd, and one of its shareholders, Ma

ria. Maria wants advice on the tax consequences of selling some of her shares back to Granada Ltd. Granada Ltd wants advice on the corporation tax and value added tax (VAT) implications of the recent acquisition of an unincorporated business.

Maria:

– Is resident and domiciled in the UK.

– Is a higher rate taxpayer and will remain so in the future.

– Has already realised chargeable gains of ￡15,000 in the tax year 2015/16.

Shares in Granada Ltd:

– Maria subscribed for 10,000 ￡1 ordinary shares in Granada Ltd at par in June 2006.

– Maria is one of four equal shareholders and directors of Granada Ltd.

– Maria intends to sell either 2,700 or 3,200 shares back to the company on 31 March 2016 at their current market value of ￡12·80 per share.

– All of the conditions for capital treatment are satisfied, except for, potentially, the condition relating to the reduction in the level of shareholding.

Granada Ltd:

– Is a UK resident trading company which manufactures knitwear.

– Prepares accounts to 31 December each year.

– Is registered for VAT.

– Acquired the trade and assets of an unincorporated business, Starling Partners, on 1 January 2016.

Starling Partners:

– Had been trading as a partnership for many years as a wholesaler of handbags within the UK.

– Starling Partners’ main assets comprise a freehold commercial building and its ‘Starling’ brand, which were valued on acquisition by Granada Ltd at ￡105,000 and ￡40,000 respectively.

– Is registered for VAT.

– The transfer of its trade and assets to Granada Ltd qualified as a transfer of a going concern (TOGC) for VAT purposes.

– The business is forecast to make a trading loss of ￡130,000 in the year ended 31 December 2016.

Granada Ltd – results and proposed expansion:

– The knitwear business is expected to continue making a taxable trading profit of around ￡100,000 each year.

– Granada Ltd has no non-trading income but realised a chargeable gain of ￡10,000 on 1 March 2016.

– Granada Ltd is considering expanding the wholesale handbag trade acquired from Starling Partners into the export market from 1 January 2017.

– Granada Ltd anticipates that this expansion will result in the wholesale handbag trade returning a profit of ￡15,000 in the year ended 31 December 2017.

Required:

(a) (i) Explain, with the aid of calculations, why the capital treatment WILL NOT apply if Maria sells 2,700 of her shares back to Granada Ltd, but WILL apply if, alternatively, she sells back 3,200 shares. (4 marks)

(ii) Calculate Maria’s after-tax proceeds per share if she sells:

(1) 2,700 shares back to Granada Ltd; and alternatively

(2) 3,200 shares back to Granada Ltd. (4 marks)

(b) (i) Describe the corporation tax treatment of the acquisition of the ‘Starling’ brand by Granada Ltd, if no charge for amortisation was required in its statement of profit or loss. (3 marks)

(ii) Discuss how Granada Ltd could obtain relief for the trading loss expected to be incurred by the trade acquired from Starling Partners, if it does not wish to carry any of the loss back. (5 marks)

(c) Explain the value added tax (VAT) implications for Granada Ltd in respect of the acquisition of the business of Starling Partners, and the additional information needed in relation to the building to fully clarify the VAT position. (4 marks)

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第4题

5 （a) Carver Ltd was incorporated and began trading in August 2002. It is a close company

5 (a) Carver Ltd was incorporated and began trading in August 2002. It is a close company with no associated

companies. It has always prepared accounts to 31 December and will continue to do so in the future.

It has been decided that Carver Ltd will sell its business as a going concern to Blade Ltd, an unconnected

company, on 31 July 2007. Its premises and goodwill will be sold for ￡2,135,000 and ￡290,000 respectively

and its machinery and equipment for ￡187,000. The premises, which do not constitute an industrial building,

were acquired on 1 August 2002 for ￡1,808,000 and the goodwill has been generated internally by the

company. The machinery and equipment cost ￡294,000; no one item will be sold for more than its original cost.

The tax adjusted trading profit of Carver Ltd in 2007, before taking account of both capital allowances and the

sale of the business assets, is expected to be ￡81,000. The balance on the plant and machinery pool for the

purposes of capital allowances as at 31 December 2006 was ￡231,500. Machinery costing ￡38,000 was

purchased on 1 March 2007. Carver Ltd is classified as a small company for the purposes of capital allowances.

On 1 August 2007, the proceeds from the sale of the business will be invested in either an office building or a

portfolio of UK quoted company shares, as follows:

Office building

The office building would be acquired for ￡3,100,000; the vendor is not registered for value added tax (VAT).

Carver Ltd would borrow the additional funds required from a UK bank. The building is let to a number of

commercial tenants who are not connected with Carver Ltd and will pay rent, in total, of ￡54,000 per calendar

quarter, in advance, commencing on 1 August 2007. The company’s expenditure for the period from 1 August

2007 to 31 December 2007 is expected to be:

￡

Loan interest payable to UK bank 16,000

Building maintenance costs 7,500

Share portfolio

Shares would be purchased for the amount of the proceeds from the sale of the business with no need for further

loan finance. It is estimated that the share portfolio would generate dividends of ￡36,000 and capital gains, after

indexation allowance, of ￡10,000 in the period from 1 August 2007 to 31 December 2007.

All figures are stated exclusive of value added tax (VAT).

Required:

(i) Taking account of the proposed sale of the business on 31 July 2007, state with reasons the date(s) on

which Carver Ltd must submit its corporation tax return(s) for the year ending 31 December 2007.

(2 marks)

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第5题

Due to the failure to settle the debts due, Jianshe Garment Trading Co Ltd （Jianshe Co) wa

Due to the failure to settle the debts due, Jianshe Garment Trading Co Ltd (Jianshe Co) was declared bankrupt by its creditors. In October 2010 the court rendered an order to accept the application of bankruptcy and designated a bankruptcy administrator. During the process of bankruptcy liquidation the bankruptcy administrator found that Jianshe Co had given up a credit of RMB 200,000 yuan owed by its affiliate enterprise in August 2009.

The bankruptcy administrator also found that some shareholders of Jianshe Co failed to made full capital contributions as prescribed in the agreement of incorporation.

Required:

Answer the following questions in accordance with the Enterprise Bankruptcy Law of China, and give your reasons for your answer:

(a) (i) State whether the action of giving up credit can be revoked during the process of liquidation; (4 marks)

(ii) State whether the court should grant an order to revoke the act of giving up credit. (3 marks)

(b) State how to deal with the matter of the lack of full capital contributions by some of the shareholders of Jianshe Co. (3 marks)

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第6题

3 Moffat Ltd, which commenced trading on 1 December 2002, supplies and fits tyres and exha

ust pipes and services

motor vehicles at thirty locations. The directors and middle management are based at the Head Office of Moffat Ltd.

Each location has a manager who is responsible for day-to-day operations and is supported by an administrative

assistant. All other staff at each location are involved in fitting and servicing operations.

The directors of Moffat Ltd are currently preparing a financial evaluation of an investment of ￡2 million in a new IT

system for submission to its bank. They are concerned that sub-optimal decisions are being made because the current

system does not provide appropriate information throughout the organisation. They are also aware that not all of the

benefits from the proposed investment will be quantitative in nature.

Required:

(a) Explain the characteristics of THREE types of information required to assist in decision-making at different

levels of management and on differing timescales within Moffat Ltd, providing TWO examples of information

that would be appropriate to each level. (10 marks)

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第7题

3 Palm plc recently acquired 100% of the ordinary share capital of Nikau Ltd from Facet Lt

d. Palm plc intends to use

Nikau Ltd to develop a new product range, under the name ‘Project Sabal’. Nikau Ltd owns shares in a non-UK

resident company, Date Inc.

The following information has been extracted from client files and from a meeting with the Finance Director of Palm

plc.

Palm plc:

– Has more than 40 wholly owned subsidiaries such that all group companies pay corporation tax at 30%.

– All group companies prepare accounts to 31 March.

– Acquired Nikau Ltd on 1 November 2007 from Facet Ltd, an unrelated company.

Nikau Ltd:

– UK resident company that manufactures domestic electronic appliances for sale in the European Union (EU).

– Large enterprise for the purposes of the enhanced relief available for research and development expenditure.

– Trading losses brought forward as at 1 April 2007 of ￡195,700.

– Budgeted taxable trading profit of ￡360,000 for the year ending 31 March 2008 before taking account of ‘Project

Sabal’.

– Dividend income of ￡38,200 will be received in the year ending 31 March 2008 in respect of the shares in Date

Inc.

‘Project Sabal’:

– Development of a range of electronic appliances, for sale in North America.

– Project Sabal will represent a significant advance in the technology of domestic appliances.

– Nikau Ltd will spend ￡70,000 on staffing costs and consumables researching and developing the necessary

technology between now and 31 March 2008. Further costs will be incurred in the following year.

– Sales to North America will commence in 2009 and are expected to generate significant profits from that year.

Shares in Date Inc:

– Nikau Ltd owns 35% of the ordinary share capital of Date Inc.

– The shares were purchased from Facet Ltd on 1 June 2003 for their market value of ￡338,000.

– The sale was a no gain, no loss transfer for the purposes of corporation tax.

– Facet Ltd purchased the shares in Date Inc on 1 March 1994 for ￡137,000.

Date Inc:

– A controlled foreign company resident in the country of Palladia.

– Annual chargeable profits arising out of property investment activities are approximately ￡120,000, of which

approximately ￡115,000 is distributed to its shareholders each year.

The tax system in Palladia:

– No taxes on income or capital profits.

– 4% withholding tax on dividends paid to shareholders resident outside Palladia.

Required:

(a) Prepare detailed explanatory notes, including relevant supporting calculations, on the effect of the following

issues on the amount of corporation tax payable by Nikau Ltd for the year ending 31 March 2008.

(i) The costs of developing ‘Project Sabal’ and the significant commercial changes to the company’s

activities arising out of its implementation. (8 marks)

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第8题

6 Assume today’s date is 16 April 2005.Henry, aged 48, is the managing director of Happy H

6 Assume today’s date is 16 April 2005.

Henry, aged 48, is the managing director of Happy Home Ltd, an unquoted UK company specialising in interior

design. He is wealthy in his own right and is married to Helen, who is 45 years old. They have two children – Stephen,

who is 19, and Sally who is 17.

As part of his salary, Henry was given 3,000 shares in Happy Home Ltd with an option to acquire a further 10,000

shares. The options were granted on 15 July 2003, shortly after the company started trading, and were not part of

an approved share option scheme. The free shares were given to Henry on the same day.

The exercise price of the share options was set at the then market value of ￡1·00 per share. The options are not

capable of being exercised after 10 years from the date of grant. The company has been successful, and the current

value of the shares is now ￡14·00 per share. Another shareholder has offered to buy the shares at their market value,

so Henry exercised his share options on 14 April 2005 and will sell the shares next week, on 20 April 2005.

With the company growing in size, Henry wishes to recruit high quality staff, but the company lacks the funds to pay

them in cash. Henry believes that giving new employees the chance to buy shares in the company would help recruit

staff, as they could share in the growth in value of Happy Home Ltd. Henry has heard that there is a particular share

scheme that is suitable for small, fast growing companies. He would like to obtain further information on how such

a scheme would work.

Henry has accumulated substantial assets over the years. The family house is owned jointly with Helen, and is worth

￡650,000. Henry has a ￡250,000 mortgage on the house. In addition, Henry has liquid assets worth ￡340,000

and Helen has shares in quoted companies currently worth ￡125,000. Henry has no forms of insurance, and believes

he should make sure that his wealth and family are protected. He is keen to find out what options he should be

considering.

Required:

(a) (i) State how the gift of the 3,000 shares in Happy Home Ltd was taxed. (1 mark)

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第9题

4 Assume today’s date is 15 May 2005.In March 1999, Bob was made redundant from his job as

4 Assume today’s date is 15 May 2005.

In March 1999, Bob was made redundant from his job as a furniture salesman. He decided to travel round the world,

and did so, returning to the UK in May 2001. Bob then decided to set up his own business selling furniture. He

started trading on 1 October 2001. After some initial success, the business made losses as Bob tried to win more

customers. However, he was eventually successful, and the business subsequently made profits.

The results for Bob’s business were as follows:

Period Schedule D Case I

Trading Profits/(losses)

￡

1 October 2001 – 30 April 2002 13,500

1 May 2002 – 30 April 2003 (18,000)

1 May 2003 – 30 April 2004 28,000

Bob required funds to help start his business, so he raised money in three ways:

(1) Bob is a keen cricket fan, and in the 1990s, he collected many books on cricket players. To raise money, Bob

started selling books from his collection. These had risen considerably in value and sold for between ￡150 and

￡300 per book. None of the books forms part of a set. Bob created an internet website to advertise the books.

Bob has not declared this income, as he believes that the proceeds from selling the books are non-taxable.

(2) He disposed of two paintings and an antique silver coffee set at auction on 1 December 2004, realising

chargeable gains totalling ￡23,720.

(3) Bob took a part time job in a furniture store on 1 January 2003. His annual salary has remained at ￡12,600

per year since he started this employment.

Bob has 5,000 shares in Willis Ltd, an unquoted trading company based in the UK. He subscribed for these shares

in August 2000, paying ￡3 per share. On 1 December 2004, Bob received a letter informing him that the company

had gone into receivership. As a result, his shares were almost worthless. The receivers dealing with the company

estimated that on the liquidation of the company, he would receive no more than 10p per share for his shareholding.

He has not yet received any money.

Required:

(a) Write a letter to Bob advising him on whether or not he is correct in believing that his book sales are nontaxable.

Your advice should include reference to the badges of trade and their application to this case.

(9 marks)

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第10题

Section B – TWO questions ONLY to be attemptedYour client, Eric, requires advice on the ca

Section B – TWO questions ONLY to be attempted

Your client, Eric, requires advice on the capital gains tax implications arising from the receipt of insurance proceeds and the disposal of some shares, and the inheritance tax reliefs available in respect of assets in his estate at death. His son Zak requires advice regarding the application of the personal service company (IR35) legislation.

Eric:

– Is UK resident and domiciled.

– Is a higher rate taxpayer.

– Is in ill health and is expected to die within the next few months.

Capital transactions in the tax year 2014/15:

– Eric made no disposals for capital gains tax purposes in the tax year 2014/15 other than those detailed below.

– Eric received insurance proceeds of ￡10,000 following damage to a valuable painting.

– Eric sold half of his shareholding in Malaga plc for ￡11·50 per share.

Damaged painting:

– Eric purchased the painting for ￡46,000 in July 2012.

– The painting was damaged in October 2014 such that immediately afterwards its value fell to ￡38,000.

– The insurance proceeds of ￡10,000 were received by Eric on 1 December 2014.

– Eric has not had the painting repaired.

Malaga plc shares:

– Malaga plc is a quoted trading company with 200,000 issued shares.

– 80% of Malaga plc’s chargeable assets have always been chargeable business assets.

– Eric was given 12,000 shares in Malaga plc by his sister on 1 April 2010, when they were valued at ￡126,000.

– Eric’s sister had purchased the shares for ￡96,000 on 1 March 2009.

– Gift relief was claimed in respect of the gift of the shares to Eric on 1 April 2010.

– Eric paid the inheritance tax arising in respect of this gift following his sister’s death on 1 September 2011.

– Eric has never worked for Malaga plc.

– Eric sold 6,000 shares in Malaga plc on 1 March 2015.

Assets owned by Eric and a previous lifetime gift:

– Eric owns farmland in the UK, which has been leased to a tenant farmer for the last ten years.

– The farmland has a market value of ￡420,000 and an agricultural value of ￡340,000.

– Eric’s other assets, excluding the remaining Malaga plc shares, are valued at ￡408,000.

– Eric has made only one previous lifetime gift, of ￡60,000 cash to his son Zak on 1 July 2009.

Zak:

– Is the sole shareholder, director and employee of Yoyo Ltd, a company which provides consultancy services.

– In the year ended 31 March 2016, Yoyo Ltd’s gross fee income from relevant engagements performed by Zak will be ￡110,000.

– In the tax year 2015/16, Zak will draw a salary of ￡24,000 and dividends of ￡50,000 from Yoyo Ltd.

– Neither Yoyo Ltd nor Zak has any other source of income.

Required:

(a) Calculate Eric’s total after-tax proceeds in respect of the two capital gains tax disposals in the tax year 2014/15. (6 marks)

(b) (i) On the assumption that Eric dies on 31 March 2016, advise on the availability and effect (if any), of agricultural property relief, business property relief and quick succession relief in respect of the farmland and the retained shares in Malaga plc.

Note: You are not required to prepare calculations for this part of the question. (6 marks)

(ii) Explain, with the aid of calculations, the impact on the inheritance tax liability arising on Eric’s death if Eric does not die until 1 August 2016. (3 marks)

(c) Calculate Zak’s taxable income for the tax year 2015/16 if the personal service company (IR35) legislation were to apply to the fee income received by Yoyo Ltd. (5 marks)

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