看看有你所在的山西省有上榜吗——ACCA中国考点分布城市

正确答案：
(b) Report to the management of Razor Ltd
To           The management of Razor Ltd
From       Tax advisers
Date         6 June 2007
Subject    The proposed activities of Cutlass Inc
(i) Rate of tax on profits of Cutlass Inc
When considering the manner in which the profits of Cutlass Inc will be taxed it must be recognised that the system of
corporation tax in Sharpenia is the same as that in the UK.
The profits of Cutlass Inc will be subject to corporation tax in the country in which it is resident or where it has a
permanent establishment. It is desirable for the profits of Cutlass Inc to be taxed in the UK rather than in Sharpenia as
the rate of corporation tax in the UK on annual profits of ￡120,000 will be 19% whereas in Sharpenia the rate of tax
would be 38%.
Residency of Cutlass Inc
Cutlass Inc will be resident in Sharpenia, because it is incorporated there. However, it will also be resident in the UK if
it is centrally managed and controlled from the UK. For this to be the case, Amy and Ben should hold the company’s
board meetings in the UK.
Under the double tax treaty between the UK and Sharpenia, a company resident in both countries is treated as being
resident in the country where it is effectively managed and controlled. For Cutlass Inc to be treated as UK resident under
the treaty, Amy and Ben would need to ensure that all key management and commercial decisions are made in the UK
and not in Sharpenia.
Permanent establishment
A permanent establishment is a fixed place of business, including an office, factory or workshop, through which the
business of an enterprise is carried on. A permanent establishment will also exist in a country if contracts in the
company’s name are habitually concluded there.
The trading profits of Cutlass Inc will be taxable in Sharpenia if they are derived from a permanent establishment in
Sharpenia even if it can be established that Cutlass Inc is UK resident under the double tax treaty.
Double taxation
If Cutlass Inc is UK resident but has a permanent establishment in Sharpenia, its trading profits will be subject to
corporation tax in both the UK and Sharpenia with double tax relief available in the UK. The double tax relief will be the
lower of the UK tax and the Sharpenian tax on the trading profits. Accordingly, as the rate of tax is higher in Sharpenia
than it is in the UK, there will be no UK tax to pay on the company’s trading profits and the rate of tax on the profits
would be the rate in Sharpenia, i.e. 38%.
If Cutlass Inc is UK resident and does not have a permanent establishment in Sharpenia, its profits will be taxable in
the UK at the rate of 19% and not in Sharpenia.

正确答案：
(c) (i) Organic Foods Ltd (OFL) with a market share of 6·66% is the market leader at 30 November 2005 and is forecast to
have a market share of 8% by 30 November 2007. Operating profits appear to be healthy and therefore it seems
reasonable to regard OFL as a current ‘strength’ of Diverse Holdings Plc. This is supported by the fact that OFL has built
up a very good reputation as a supplier of quality produce.
Haul Trans Ltd was acquired on 1 December 2005 and has a demonstrable record of recent profitability. It is noticeable
that the profitability of HTL is forecast to increase by 40% (excluding inflation) during its first two years of ownership.
No one organisation appears to dominate the market. Forecast profits are expected to grow significantly from an almost
static turnover and thus more information is required regarding how this increase in profitability is to be achieved.
Management may have identified opportunities for achieving significant cost savings and/or forming business
relationships with new and more profitable customers, while ceasing to service those customers who are less profitable.
Kitchen Appliances Ltd (KAL) has been identified as both a weakness and threat. KAL’s market is slowly contracting,
but its share is falling more quickly. It was almost the market leader at 30 November 2005. Judging by its fall in the
level of operating profit KAL is carrying heavy fixed costs which must make it more difficult to compete. Indeed, it is
forecast to make a loss during the year ending 30 November 2007. KAL has suffered from squeezed margins as a
consequence of competition from low cost imports. The situation may be further exacerbated as competition from abroad
intensifies.
Paper Supplies Ltd (PSL) has stood still in a growing market, one which is dominated by a single supplier. PSL appears
to be struggling to achieve any growth in turnover, profits and therefore cash flow. PSL cannot really compete with a
narrow range of products and only two customers.
Office Products Ltd (OPL) is growing but appears unable to increase its operating profit in % terms. It appears to be
operating in a high-growth market but unable to achieve a reasonable market share in spite of the fact that its products
are highly regarded by health and safety experts.

正确答案：