重庆市2019年12月ACCA考试成绩公布时间定了！

正确答案：
(b) Developing a shared culture will be one of the key determinants of whether the anticipated benefits of the acquisition actually
materialise. Due diligence procedures before the merger should have established the key people issues. This will include
reviewing the two management styles and cultures. Clearly these are very different, looking at internal communication pre
and post acquisition, understanding the nature of reward systems in the firm to be acquired, assessing the nature of training
programmes in the firm both before and after the acquisition and attempting to gauge existing employee attitudes towards
Papier Presse and the likely reaction to the acquisition. Reviewing areas where there have been significant staff problems and
consequent negotiations will also be an important clue as to employee attitudes and morale. ‘Hard’ people issues including
pensions, management rewards, health insurance and redundancy terms will need to be realistically assessed and the
implications for both the price paid for the company and subsequent integration fully understood. All too often the compelling
strategic vision for the enlarged company ignores the people costs involved and the time needed to develop shared HR
systems.
Many models on culture and culture management could help to achieve a successful transition. Mintzberg’s cultural or
organisational configuration model, which would facilitate an understanding of the difference in structures and systems, could
be a useful starting point. DPP comes from a divisionalised company where the middle line managers are given considerable
autonomy in achieving agreed levels of performance. Papier Presse, with its dominance by family ownership and
management, could be argued to be entrepreneurial in character, where the owner/managers at the strategic apex of the
company operate a ‘hands-on’ approach and direct control of subordinates. Reconciling these different cultures and structures
will not be an easy task.
Lewin’s 3-step model of change can be used in helping a positive culture emerge from the combining of the two companies.
There is a need to unfreeze the current situation in which employees of both organisations are likely to be reluctant or resistant
to change. There needs to be a clear understanding of who does what in the new organisation – leadership and the role of
the French owners will be a critical factor in successfully changing the culture. Robbins emphasises the need for positive top
management role models in promoting and communicating the need for a change in culture. Policies to affect change on both
the hard and soft factors referred to above need to be in place to move the integration forward. A clear timescale and vision
for change will be a key part of the change process. Finally the systems will need to be in place to re-freeze or rather reinforce
the attitudes and behaviours necessary to achieve success in the merged organisation. Operating across national borderscreates real culture issues to be solved as shown in studies by Hofstede and Bartlett and Ghoshal.

正确答案：
(b) Rate of tax on profits of non-UK resident investee companies
Undistributed profits
The companies will be subject to tax in the countries in which they are resident; this is because of their residency status or
because they have a permanent establishment in that country. Undistributed profits will not be taxed in the UK.
The rate of tax on undistributed profits will therefore be the rate of tax in the country of residency of the respective companies.
Distributed profits with double tax treaty
The dividends received by Acrux Ltd from each of the overseas companies will be grossed up in respect of underlying tax (the
overseas corporation tax paid on the distributed profits) because Acrux Ltd will own at least 10% of the overseas companies.
The gross amount will then be included in Acrux Ltd’s profits chargeable to corporation tax.
The treaty will provide double tax relief in the UK for the overseas tax suffered in respect of each dividend up to a maximum
of the UK tax on the grossed up overseas dividend. As a result of the double tax relief, the overall rate of tax suffered will be
the higher of the UK rate paid by Acrux Ltd and the overseas tax rate borne by the overseas company.
Where the rate of overseas tax in respect of a particular dividend exceeds the rate of corporation tax in the UK, excess foreign
tax will arise. This can be relieved, via onshore pooling, against the UK tax due on those dividends where the rate of tax in
the UK exceeds the rate overseas. This will reduce the overall rate of tax suffered on the total overseas profits of the overseas
companies as a whole.
Distributed profits with no double tax treaty
Where there is no double tax treaty, unilateral double tax relief will be available in the UK. This relief will operate in the same
way as double tax relief under a double tax treaty such that the overall rate of tax on each dividend will be the higher of the
UK rate paid by Acrux Ltd and the overseas rate borne by the overseas company. Relief via onshore pooling will also be
available.

正确答案：