四川省2019年12月ACCA考试成绩公布时间定了！

正确答案：
(c) Ban on emptying waste water
(i) Matter
■ $0·9m provision for upgrading the process represents 45% PBT and is very material. This provision is also
material to the balance sheet (2·7% of total assets).
■ The provision for penalties is immaterial (2·2% PBT and 0·1% total assets).
■ The ban is an adjusting post balance sheet event in respect of the penalties (IAS 10). It provides evidence that at
the balance sheet date Keffler was in contravention of local government standards. Therefore it is correct (in
accordance with IAS 37) that a provision has been made for the penalties. As the matter is not material inclusion
in ‘other provisions’ is appropriate.
■ However, even if Keffler has a legal obligation to meet minimum standards, there is no obligation for upgrading the
purifying process at 31 March 2006 and the $0·9m provision should be written back.
■ If the provision for upgrading is not written back the audit opinion should be qualified ‘except for’ (disagreement).
■ Keffler does not even have a contingent liability for upgrading the process because there is no present obligation to
do so. The obligation is to stop emptying unclean water into the river. Nor is there a possible obligation whose
existence will be confirmed by an uncertain future event not wholly within Keffler’s control.
Tutorial note: Consider that Keffler has alternatives wholly within its control. For example, it could ignore the ban
and incur fines, or relocate/close this particular plant/operation or perhaps dispose of the water by alternative
means.
■ The need for a technological upgrade may be an indicator of impairment. Management should have carried out
an impairment test on the carrying value of the water purifying process and recognised any impairment loss in the
profit for the year to 31 March 2006.
■ Management’s intention to upgrade the process is more appropriate to an environmental responsibility report (if
any).
■ Whether there is any other information in documents containing financial statements.
(ii) Audit evidence
■ Penalty notices of fines received to confirm amounts and period/dates covered.
■ After-date payment of fines agreed to the cash book.
■ A copy of the ban and any supporting report on the local government’s findings.
■ Minutes of board meetings at which the ban was discussed confirming management’s intentions (e.g. to upgrade
the process).
Tutorial note: This may be disclosed in the directors’ report and/or as a non-adjusting post balance sheet event.
■ Any tenders received/costings for upgrading.
Tutorial note: This will be relevant if, for example, capital commitment authorised (by the board) but not
contracted for at the year end are disclosed in the notes to the financial statements.
■ Physical inspection of the emptying point at the river to confirm that Keffler is not still emptying waste water into
it (unless the upgrading has taken place).
Tutorial note: Thereby incurring further penalties.

正确答案：

(ii) As far as annual agreements relating to property work are concerned, HLP had a take up rate of 82·5% whereas MAS
had a take up rate of only 50%. Therefore, HLP has ‘lost out’ to competitor MAS in relative financial terms as regards
the ‘take-up’ of consultations relating to property work. This is because both HLP and MAS received an annual fee from
each property client irrespective of the number of consultations given. MAS should therefore have had a better profit
margin from this area of business than HLP. However, the extent to which HLP has ‘lost out’ cannot be quantified since
we would need to know the variable costs per consultation and this detail is not available. What we do know is that
HLP earned actual revenue per effective consultation amounting to ￡90·90 whereas the budgeted revenue per
consultation amounted to ￡100. MAS earned ￡120 per effective consultation.
The same picture emerges from annual agreements relating to commercial work. HLP had a budgeted take up rate of
50%, however the actual take up rate during the period was 90%. MAS had an actual take up rate of 50%. The actual
revenue per effective consultation earned by HLP amounted to ￡167 whereas the budgeted revenue per consultation
amounted to ￡300. MAS earned ￡250 per effective consultation.
There could possibly be an upside to this situation for HLP in that it might be the case that the uptake of 90% of
consultations without further charge by clients holding annual agreements in respect of commercial work might be
indicative of a high level of customer satisfaction. It could on the other hand be indicative of a mindset which says ‘I
have already paid for these consultations therefore I am going to request them’.
(iii) Budgeted and actual salaries in HLP were ￡50,000 per annum, per advisor. Two additional advisors were employed
during the year in order to provide consultations in respect of commercial work. MAS paid a salary of ￡60,000 to each
advisor which is 20% higher than the salary of ￡50,000 paid to each advisor by HLP. Perhaps this is indicative that
the advisors employed by MAS are more experienced and/or better qualified than those employed by HLP.
HLP paid indemnity insurance of ￡250,000 which is ￡150,000 (150%) more than the amount of ￡100,000 paid by
MAS. This excess cost may well have arisen as a consequence of successful claims against HLP for negligence in
undertaking commercial work. It would be interesting to know whether HLP had been the subject of any successful
claims for negligent work during recent years as premiums invariably reflect the claims history of a business. Rather
worrying is the fact that HLP was subject to three such claims during the year ended 31 May 2007.
Significant subcontract costs were incurred by HLP during the year probably in an attempt to satisfy demand and retain
the goodwill of its clients. HLP incurred subcontract costs in respect of commercial properties which totalled ￡144,000.
These consultations earned revenue amounting to (320 x ￡150) = ￡48,000, hence a loss of ￡96,000 was incurred
in this area of the business.
HLP also paid ￡300,000 for 600 subcontract consultations in respect of litigation work. These consultations earned
revenue amounting to (600 x ￡250) = ￡150,000, hence a loss of ￡150,000 was incurred in this area of the business.
In contrast, MAS paid ￡7,000 for 20 subcontract consultations in respect of commercial work and an identical amount
for 20 subcontract consultations in respect of litigation work. These consultations earned revenue amounting to
20 x (￡150 + ￡200) =￡7,000. Therefore, a loss of only ￡7,000 was incurred in respect of subcontract consultations
by MAS.
Other operating expenses were budgeted at 53·0% of sales revenue. The actual level incurred was 40·7% of sales
revenue. The fixed/variable split of such costs is not given but it may well be the case that the fall in this percentage is
due to good cost control by HLP. However, it might simply be the case that the original budget was flawed. Competitor
MAS would appear to have a slightly superior cost structure to that of HLP since its other operating expenses amounted
to 38·4% of sales revenue. Further information is required in order to draw firmer conclusions regarding cost control
within both businesses.

正确答案：
(b) There are several matters that Irroy will need to be aware of in relation to value added tax and corporation tax. These are set
out below.
Residence of subsidiary
Irroy will want to ensure that the subsidiary is treated as being resident in the Republic of Ireland. It will then pay corporation
tax on its profits at lower rates than in the UK. The country of incorporation usually claims taxing rights, but this is not by
itself sufficient. Irroy needs to be aware that a company can be treated as UK resident by virtue of the location of its central
management and control. This is usually defined as being where the board of directors meets to make strategic decisions. As
a result, Irroy needs to ensure that board meetings are conducted outside the UK.
If Green Limited is treated as being UK resident, it will be taxed in the UK on its worldwide income, including that arising in
the Republic of Ireland. However, as it will be conducting trading activities in the Republic of Ireland, Green Limited will also
be treated as being Irish resident as its activities in that country are likely to constitute a permanent establishment. Thus it
may also suffer tax in the Republic of Ireland as a consequence, although double tax relief will be available (see later).
A permanent establishment is broadly defined as a fixed place of business through which a business is wholly or partly carried
on. Examples of a permanent establishment include an office, factory or workshop, although certain activities (such as storage
or ancillary activities) can be excluded from the definition.
If Green Limited is treated as being an Irish resident company, any dividends paid to Aqua Limited will be taxed under
Schedule D Case V in the UK. Despite being non resident, Green Limited will still count as an associate of the existing UK
companies, and may affect the rates of tax paid by Aqua Limited and Aria Limited in the UK. However, as a non UK resident
company, Green Limited will not be able to claim losses from the UK companies by way of group relief.
Double tax relief
If Green Limited is treated as UK resident, corporation tax at UK rates will be payable on all profits earned. However, income
arising in the Republic of Ireland is likely to have been taxed in that country also by virtue of having a permanent
establishment located there. As the same profits have been taxed twice, double tax relief is available, either by reference to
the tax treaty between the UK and the Republic of Ireland, or on a unilateral basis, where the UK will give relief for the foreign
tax suffered.
If Green Limited is treated as an Irish resident company, it will pay tax in the Republic of Ireland, based on its worldwide
taxable profits. However, any repatriation of profits to the UK by dividend will be taxed on a receipts basis in the UK. Again,
double tax relief will be available as set out above.
Double tax relief is available against two types of tax. For payments made by Green Limited to Aqua Limited on which
withholding tax has been levied, credit will be given for the tax withheld. In addition, relief is available for the underlying tax
where a dividend is received from a foreign company in which Aqua Limited owns at least 10% of the voting power. The
underlying tax is the tax attributable to the relevant profits from which the dividend was paid.
Double tax relief is given at the lower rate of the UK tax and the foreign tax (withholding and underlying taxes) suffered.
Transfer pricing
Where groups have subsidiaries in other countries, they may be tempted to divert profits to subsidiaries which pay tax at lower
rates. This can be achieved by artificially changing the prices charged (known as the transfer price) between the group
companies. While they can do this commercially through common control, anti avoidance legislation seeks to correct this by
ensuring that for taxation purposes, profits on such intra-group transactions are calculated as if the transactions were carried
out on an arms length basis. Since 1 April 2004, this legislation can also be applied to transactions between UK group
companies.
If Green Limited is treated as a UK resident company, the group’s status as a small or medium sized enterprise means that
transfer pricing issues will not apply to transactions between Green Limited and the other UK group companies.
If Green Limited is an Irish resident company, transfer pricing issues will not apply to transactions between Green Ltd and the
UK resident companies because of the group’s status as a small or medium-sized enterprise and the existence of a double
tax treaty, based on the OECD model, between the UK and the Republic of Ireland.
Controlled foreign companies
Tax legislation exists to stop a UK company accumulating profits in a foreign subsidiary which is subject to a low tax rate.
Such a subsidiary is referred to as a controlled foreign company (CFC), and exists where:
(1) the company is resident outside the UK, and
(2) is controlled by a UK resident entity or persons, and
(3) pays a ‘lower level of tax’ in its country of residence.
A lower level of tax is taken to be less than 75% of the tax that would have been payable had the company been UK resident.
If Green Limited is an Irish resident company, it will be paying corporation tax at 12·5% so would appear to be caught by
the above rules and is therefore likely to be treated as a CFC.
Where a company is treated as a CFC, its profits are apportioned to UK resident companies entitled to at least 25% of its
profits. For Aqua Limited, which would own 100% of the shares in Green Limited, any profits made by Green Limited would
be apportioned to Aqua Limited as a deemed distribution. Aqua Limited would be required to self-assess this apportionment
on its tax return and pay UK tax on the deemed distribution (with credit being given for the Irish tax suffered).
There are some exemptions which if applicable the CFC legislation does not apply and no apportionments of profits will be
made. These include where chargeable profits of the CFC do not exceed ￡50,000 in an accounting period, or where the CFC
follows an acceptable distribution policy (distributing at least 90% of its chargeable profits within 18 months of the relevant
period).
Value added tax (VAT)
Green Limited will be making taxable supplies in the Republic of Ireland and thus (subject to exceeding the Irish registration
limit) liable to register for VAT there. If Green Limited is registered for VAT in the Republic of Ireland, then supplies of goods
made from the UK will be zero rated. VAT on the goods will be levied in the Republic of Ireland at a rate of 21%. Aqua Limited
will need to have proof of supply in order to apply the zero rate, and will have to issue an invoice showing Green Limited’s
Irish VAT registration number as well as its own. In the absence of such evidence/registration, Aqua Limited will have to treat
its transactions with Green Limited as domestic sales and levy VAT at the UK standard rate of 17·5%.
In addition to making its normal VAT returns, Aqua Limited will also be required to complete an EU Sales List (ESL) statement
each quarter. This provides details of the sales made to customers in the return period – in this case, Green Limited. Penalties
can be applied for inaccuracies or non-compliance.

正确答案：B
430,000 x 5% = 21,500 – 18,000 + 28,000