ACCAF1考试-会计师与企业（基础阶段）模拟试题(2020-10-11)

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(ii) Inheritance tax administration
The tax on Debbie’s estate (personalty and realty) would be paid by the personal representatives, usually an executor.
Inheritance tax is due six months from the end of the month in which death occurred (31 December 2005) or the date
on which probate is obtained (if earlier). However, an instalment option is available for certain assets, which includes
land and buildings i.e. the residence whereby the tax can be paid in 10 equal annual instalments.

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(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) There are many reasons that could be discussed in support of the view that net present value (NPV) is superior to other
investment appraisal methods.
NPV considers cash flows
This is the reason why NPV is preferred to return on capital employed (ROCE), since ROCE compares average annual
accounting profit with initial or average capital invested. Financial management always prefers cash flows to accounting profit,
since profit is seen as being open to manipulation. Furthermore, only cash flows are capable of adding to the wealth of
shareholders in the form. of increased dividends. Both internal rate of return (IRR) and Payback also consider cash flows.
NPV considers the whole of an investment project
In this respect NPV is superior to Payback, which measures the time it takes for an investment project to repay the initial
capital invested. Payback therefore considers cash flows within the payback period and ignores cash flows outside of the
payback period. If Payback is used as an investment appraisal method, projects yielding high returns outside of the payback
period will be wrongly rejected. In practice, however, it is unlikely that Payback will be used alone as an investment appraisal
method.
NPV considers the time value of money
NPV and IRR are both discounted cash flow (DCF) models which consider the time value of money, whereas ROCE and
Payback do not. Although Discounted Payback can be used to appraise investment projects, this method still suffers from the
criticism that it ignores cash flows outside of the payback period. Considering the time value of money is essential, since
otherwise cash flows occurring at different times cannot be distinguished from each other in terms of value from the
perspective of the present time.
NPV is an absolute measure of return
NPV is seen as being superior to investment appraisal methods that offer a relative measure of return, such as IRR and ROCE,
and which therefore fail to reflect the amount of the initial investment or the absolute increase in corporate value. Defenders
of IRR and ROCE respond that these methods offer a measure of return that is understandable by managers and which can
be intuitively compared with economic variables such as interest rates and inflation rates.
NPV links directly to the objective of maximising shareholders’ wealth
The NPV of an investment project represents the change in total market value that will occur if the investment project is
accepted. The increase in wealth of each shareholder can therefore be measured by the increase in the value of their
shareholding as a percentage of the overall issued share capital of the company. Other investment appraisal methods do not
have this direct link with the primary financial management objective of the company.
NPV always offers the correct investment advice
With respect to mutually exclusive projects, NPV always indicates which project should be selected in order to achieve the
maximum increase on corporate value. This is not true of IRR, which offers incorrect advice at discount rates which are less
than the internal rate of return of the incremental cash flows. This problem can be overcome by using the incremental yield
approach.
NPV can accommodate changes in the discount rate
While NPV can easily accommodate changes in the discount rate, IRR simply ignores them, since the calculated internal rate
of return is independent of the cost of capital in all time periods.
NPV has a sensible re-investment assumption
NPV assumes that intermediate cash flows are re-invested at the company’s cost of capital, which is a reasonable assumption
as the company’s cost of capital represents the average opportunity cost of the company’s providers of finance, i.e. it
represents a rate of return which exists in the real world. By contrast, IRR assumes that intermediate cash flows are reinvested
at the internal rate of return, which is not an investment rate available in practice,
NPV can accommodate non-conventional cash flows
Non-conventional cash flows exist when negative cash flows arise during the life of the project. For each change in sign there
is potentially one additional internal rate of return. With non-conventional cash flows, therefore, IRR can suffer from the
technical problem of giving multiple internal rates of return.

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