河北省2020年ACCA国际会计师报名入口及报名流程~

正确答案：

正确答案：
(b) (i) The directors of GWCC might consider any of the following specific actions in order to improve the return on the
investment:
– Attempt to raise the selling price of the Mighty Ben cake to Superstores plc. Much will depend on the nature of the
relationship in terms of mutuality of trust and co-operation between the parties. If Superstores plc are insistent on
a launch price of ￡20·25 and a mark-up of 35% on its purchase price from GWCC then this is likely to be
unsuccessful.
– Attempt to reduce the material losses in the first 600 batches of production via improved process control.
– Attempt to negotiate a retrospective rebate based on volumes of packaging purchased.
– Improve the rate of learning of the hand-skilled cake decorators via a more intensive training programme and/or
altering the flow of production.
– Undertake a thorough review of all variable overheads which have been absorbed on the basis of direct labour
hours. It might well be the case that labour is not the only ‘cost driver’ in which case variable overheads might be
overstated.
– Undertake a thorough review of all fixed overheads to ensure that they are specific to the production of the Mighty
Ben cake.
– Adopt a ‘value engineering’ approach in order to identify ‘non value added’ features/aspects of the product or
processes used to produce it. This would have to be done in conjunction with Superstores plc, but might end in a
‘win-win’ scenario.
– Ensure that all overhead expenditure will be incurred in the most ‘economic’ manner.

正确答案：D

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.