51题库考试学习网告诉你申请acca需要哪些证明资料？

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：
(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：
(b) Perfect Shopper currently has a relatively short upstream supply chain. They are bulk purchasers from established suppliers
of branded goods. Their main strength at the moment is to offer these branded goods at discounted prices to neighbourhood
shops that would normally have to pay premium prices for these goods.
In the upstream supply chain, the issue of branding is a significant one. At present, Perfect Shopper only provides branded
goods from established names to its customers. As far as the suppliers are concerned, Perfect Shopper is the customer and
the company’s regional warehouses are supplied as if they were the warehouses of conventional supermarkets. Perfect
Shopper might look at the following restructuring opportunities within this context:
– Examining the arrangements for the delivery of products from suppliers to the regional warehouses. At present this is in
the hands of the suppliers or contractors appointed by suppliers. It appears that when Perfect Shopper was established
it decided not to contract its own distribution. This must now be open to review. It is likely that competitors have
established contractual arrangements with logistics companies to collect products from suppliers. Perfect Shopper must
examine this, accompanied by an investigation into downstream distribution. A significant distribution contract would
probably include the branding of lorries and vans and this would provide an opportunity to increase brand visibility and
so tackle this issue at the same time.
– Contracting the supply and distribution of goods also offers other opportunities. Many integrated logistics contractors also
supply storage and warehousing solutions and it would be useful for Perfect Shopper to evaluate the costs of these.
Essentially, distribution, warehousing and packaging could be outsourced to an integrated logistics company and Perfect
Shopper could re-position itself as a primarily sales and marketing operation.
– Finally, Perfect Shopper must review how it communicates orders and ordering requirements with its suppliers. Their
reliance on supplier deliveries suggests that the relationship is a relatively straightforward one. There may be
opportunities for sharing information and allowing suppliers access to forecasted demand. There are many examples
where organisations have allowed suppliers access to their information to reduce costs and to improve the efficiency of
the supply chain as a whole.
The suggestions listed above assume that Perfect Shopper continues to only supply branded goods. Moving further upstream
in the supply chain potentially moves the company into the manufacture and supply of goods. This will raise a number of
significant issues about the franchise itself.
At present Perfect Shopper has, by necessity, concentrated on branded goods. It has not really had to understand how these
goods sell in specific locations because it has not been able to offer alternatives. The content of the standing order reflects
how the neighbourhood shop wishes to compete in its locality. However, if Perfect Shopper decides to commission its own
brand then the breadth of products is increased. Neighbourhood shops would be able to offer ‘own brand’ products to compete
with supermarkets who also focus on own brand products. It would also increase the visibility of the brand. However, Perfect
Shopper must be sure that this approach is appropriate as a whole. It could easily produce an own brand that reduces the
overall image of the company and hence devalues the franchise. Much more research is needed to assess the viability ofproducing ‘own brand’ goods.

正确答案：
6 MONEY LAUNDERING
Tutorial note: The answer which follows is indicative of the range of points which might be made. Other relevant material will
be given suitable credit.
(a) Meaning of the term
■ Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds
of their criminal activity (‘dirty’ money) allowing them to maintain control over the proceeds and, ultimately, providing a
legitimate cover for their sources of income.
■ The term is widely defined to include:
– possessing; or
– in any way dealing with; or
– concealing
the proceeds of any crime (‘criminal property’).
■ It also includes:
– an attempt or conspiracy or incitement to commit such an offence; or
– aiding, abetting, counselling or procuring the commission of such an offence.
■ Further, it includes failure by an individual in a regulated sector to inform. the financial intelligence unit (FIU), as soon
as practicable, of knowledge or suspicion that another person is engaged in money laundering.
Tutorial note: The FIU serves as a national centre for receiving (and, as permitted, requesting), analysing and
disseminating suspicious transaction reports (STRs).