看看有你所在的广西有上榜吗——ACCA中国考点分布城市

正确答案：

(b) [Ben’s address]                                                                                                     [Firm’s address]
Dear Ben                                                                                                                              [Date]
A company purchase of own shares can be subject to capital gains treatment if certain conditions are satisfied. However, one
of these conditions is that the shares in question must have been held for a minimum period of five years. As at 1 May 2010,
your shares in Flower Limited have only been held for four years and ten months. As a result, the capital gains treatment will
not apply.
In the absence of capital gains treatment, the position on a company repurchase of its own shares is that the payment will
be treated as an income distribution (i.e. a dividend) in the hands of the recipient. The distribution element is calculated as
the proceeds received for the shares less the price paid for them. On the basis that the purchase price is ￡500,000, then the
element of distribution will be ￡499,500 (500,000 – 500). This would be taxed as follows:

正确答案：
(b) Outsourced cold storage
(i) Matters
■ Inventory at 31 March 2007 represents 21% of total assets (10·1/48·0) and is therefore a very material item in the
balance sheet.
■ The value of inventory has increased by 50% though revenue has increased by only 7·5%. Inventory may be
overvalued if no allowance has been made for slow-moving/perished items in accordance with IAS 2 Inventories.
■ Inventory turnover has fallen to 6·6 times per annum (2006 – 9·3 times). This may indicate a build up of
unsaleable items.
Tutorial note: In the absence of cost of sales information, this is calculated on revenue. It may also be expressed
as the number of days sales in inventory, having increased from 39 to 55 days.
■ Inability to inspect inventory may amount to a limitation in scope if the auditor cannot obtain sufficient audit
evidence regarding quantity and its condition. This would result in an ‘except for’ opinion.
■ Although Hogg’s monthly return provides third party documentary evidence concerning the quantity of inventory it
does not provide sufficient evidence with regard to its valuation. Inventory will need to be written down if, for
example, it was contaminated by the leakage (before being moved to Hogg’s cold storage) or defrosted during
transfer.
■ Lamont’s written representation does not provide sufficient evidence regarding the valuation of inventory as
presumably Lamont’s management did not have access to physically inspect it either. If this is the case this may
call into question the value of any other representations made by management.
■ Whether, since the balance sheet date, inventory has been moved back from Hogg’s cold storage to Lamont’s
refrigeration units. If so, a physical inspection and roll-back of the most significant fish lines should have been
undertaken.
Tutorial note: Credit will be awarded for other relevant accounting issues. For example a candidate may question
whether, for example, cold storage costs have been capitalised into the cost of inventory. Or whether inventory moves
on a FIFO basis in deep storage (rather than LIFO).
(ii) Audit evidence
■ A copy of the health and safety regulation preventing the auditor from gaining access to Hogg’s cold storage to
inspect Lamont’s inventory.
■ Analysis of Hogg’s monthly returns and agreement of significant movements to purchase/sales invoices.
■ Analytical procedures such as month-on-month comparison of gross profit percentage and inventory turnover to
identify any trend that may account for the increase in inventory valuation (e.g. if Lamont has purchased
replacement inventory but spoiled items have not been written off).
■ Physical inspection of any inventory in Lamont’s refrigeration units after the balance sheet date to confirm its
condition.
■ An aged-inventory analysis and recalculation of any allowance for slow-moving items.
■ A review of after-date sales invoices for large quantities of fish to confirm that fair value (less costs to sell) exceed
carrying amount.
■ A review of after-date credit notes for any returns of contaminated/perished or otherwise substandard fish.

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.