ACCA考试常用公式汇总，值得河南省考生收藏！

3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans to

expand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell her

shares back to the company. Once the purchase of her shares has taken place, the company intends to establish a

number of branches overseas and acquire a shareholding in a number of companies that are resident and trade in

overseas countries.

The following information has been obtained from client files and meetings with the parties involved.

Acrux Ltd:

– An unquoted UK resident company.

– Share capital consists of 50,000 ordinary shares issued at ￡1·90 per share in July 2000.

– None of the other shareholders has any connection with Spica.

The purchase of own shares:

– The company will purchase all of Spica’s shares for ￡8 per share.

– The transaction will take place by the end of 2008.

Spica:

– Purchased 8,000 shares in Acrux Ltd for ￡2 per share on 30 September 2003.

– Has no income in the tax year 2008/09.

– Has chargeable capital gains in the tax year 2008/09 of ￡3,800.

– Has houses in the UK and the country of Solaris and divides her time between them.

Investment in non-UK resident companies:

– Acrux Ltd will acquire between 15% and 20% of each of the non-UK resident companies.

– The companies will not be controlled foreign companies as the rates of tax in the overseas countries will be

between 23% and 42%.

– There may or may not be a double tax treaty between the UK and the overseas countries in which the companies

are resident. Where there is a treaty, it will be based on the OECD model treaty.

– None of the countries concerned levy withholding tax on dividends paid to UK companies.

– The directors of Acrux Ltd are concerned that the rate of tax suffered on the profits of the overseas companies

will be very high as they will be taxed in both the overseas country and in the UK.

Required:

(a) (i) Prepare detailed calculations to determine the most beneficial tax treatment of the payment Spica will

receive for her shares; (7 marks)

(ii) the panel interview with more than one interviewer. (5 marks)

2 Clifford and Amanda, currently aged 54 and 45 respectively, were married on 1 February 1998. Clifford is a higher

rate taxpayer who has realised taxable capital gains in 2007/08 in excess of his capital gains tax annual exemption.

Clifford moved into Amanda’s house in London on the day they were married. Clifford’s own house in Oxford, where

he had lived since acquiring it for ￡129,400 on 1 August 1996, has been empty since that date although he and

Amanda have used it when visiting friends. Clifford has been offered ￡284,950 for the Oxford house and has decided

that it is time to sell it. The house has a large garden such that Clifford is also considering an offer for the house and

a part only of the garden. He would then sell the remainder of the garden at a later date as a building plot. His total

sales proceeds will be higher if he sells the property in this way.

Amanda received the following income from quoted investments in 2006/07:

￡

Dividends in respect of quoted trading company shares 1,395

Dividends paid by a Real Estate Investment Trust out of tax exempt property income 485

On 1 May 2006, Amanda was granted a 22 year lease of a commercial investment property. She paid the landlord

a premium of ￡6,900 and also pays rent of ￡2,100 per month. On 1 June 2006 Amanda granted a nine year

sub-lease of the property. She received a premium of ￡14,700 and receives rent of ￡2,100 per month.

On 1 September 2006 Amanda gave quoted shares with a value of ￡2,200 to a registered charity. She paid broker’s

fees of ￡115 in respect of the gift.

Amanda began working for Shearer plc, a quoted company, on 1 June 2006 having had a two year break from her

career. She earns an annual salary of ￡38,600 and was paid a bonus of ￡5,750 in August 2006 for agreeing to

come and work for the company. On 1 August 2006 Amanda was provided with a fully expensed company car,

including the provision of private petrol, which had a list price when new of ￡23,400 and a CO2 emissions rate of

187 grams per kilometre. Amanda is required to pay Shearer plc ￡22 per month in respect of the private use of the

car. In June and July 2006 Amanda used her own car whilst on company business. She drove 720 business miles

during this two month period and was paid 34 pence per mile. Amanda had PAYE of ￡6,785 deducted from her gross

salary in the tax year 2006/07.

After working for Shearer plc for a full year, Amanda becomes entitled to the following additional benefits:

– The opportunity to purchase a large number of shares in Shearer plc on 1 July 2007 for ￡3·30 per share. It is

anticipated that the share price on that day will be at least ￡7·50 per share. The company will make an interestfree

loan to Amanda equal to the cost of the shares to be repaid in two years.

– Exclusive free use of the company sailing boat for one week in August 2007. The sailing boat was purchased by

Shearer plc in January 2005 for use by its senior employees and costs the company ￡1,400 a week in respect

of its crew and other running expenses.

Required:

(a) (i) Calculate Clifford’s capital gains tax liability for the tax year 2007/08 on the assumption that the Oxford

house together with its entire garden is sold on 31 July 2007 for ￡284,950. Comment on the relevance

to your calculations of the size of the garden; (5 marks)