2019年ACCA考试《专业会计师（专业阶段）》模拟试题(2019-03-21)

正确答案：
(b) (i) Andrew may be able to take advantage of tax reliefs under the enterprise investment scheme (EIS) provided the
necessary conditions are met. The conditions that have to be satisfied before full relief is available fall into three areas,
and broadly require that a ‘qualifying individual’ subscribes for ‘eligible shares’ in a ‘qualifying company’.
‘Qualifying Individual’
To be a qualifying individual, Andrew must not be connected with the EIS company. This means that he should not be
an employee (or, at the time the shares are issued, a director) or have an interest in (i.e. control) 30% or more of the
capital of the company. These conditions need to be satisfied throughout the period beginning two years before the share
issue and three years after the ‘relevant date’. Where the relevant date is defined as the later of the date the shares were
issued and the date on which the company commenced trading.
Andrew does not intend to become an employee (or director) of Scalar Limited, but he needs to exercise caution as to
how many shares he subscribes for. If only three investors subscribe for 100% of the shares, each will hold 33% of the
share capital. This exceeds the 30% limit and will mean that EIS relief (other than deferral relief) will not be available.
Therefore, Andrew and the other two investors should ensure not only that the potential fourth investor is recruited, but
that s/he subscribes for sufficient shares, such that none of them will hold 30% or more of the issued share capital, as
only then will they all attain qualifying individual status.
‘Eligible shares’
Qualifying shares need to be new ordinary shares which are subscribed for in cash and fully paid up at the time of issue.
The shares must not be redeemable for at least three years from the relevant date, and not carry any preferential rights
to dividends. On the basis of the information provided, the shares of Scalar Limited would qualify as eligible shares.
‘Qualifying Company’
The company must be unquoted, not controlled by another company, and engaged in qualifying business activities. The
latter requires that the company engage in a trading activity, which is carried on wholly or mainly in the UK, throughout
the three years following the relevant date. While certain trading activities, such as dealing in shares or trading in land,
are excluded, the manufacturing trade Scalar Limited proposes to carry on will qualify.
However, it is also necessary for at least 80% of the money raised to be used for the qualifying business activity within
12 months of the relevant date and the remaining 20% to be so used within the following 12 months. Andrew and the
other investors will thus have to ensure that Scalar Limited has not raised more funds than it is able to employ in the
business within the appropriate time periods.
Reliefs available:
Andrew can claim income tax relief at 20% income tax relief on the amount invested up to a maximum of ￡200,000
in any one tax year. The relief is given in the form. of a tax reducing allowance, which can reduce the investor’s income
tax liability to nil, but cannot be used to generate a tax refund. If the investment is made prior to 6 October in the tax
year, then 50% of the amount invested (up to a maximum of ￡25,000) can be treated as having been made in the
previous tax year.
Any capital gains arising on the sale of EIS shares will be fully exempt from capital gains tax provided that income tax
relief was given on the investment when made and has not been withdrawn. If the EIS shares are disposed of at a loss,
capital losses are still allowable, but reduced by the amount of any EIS relief attributable to the shares disposed of.
In addition, gains from the disposal of other assets can be deferred against the base cost of EIS shares acquired within
one year before and three years after their disposal. Such gains will, thus, not normally become chargeable until the EIS
shares themselves are disposed of. Further, for deferral relief to be available, it is not necessary for the investment to
qualify for EIS income tax relief, i.e. deferral is available even where the investor is not a qualifying individual. Thus,
Andrew could still defer the gain arising on the disposal of the residential property lease made in order to raise part of
the funds for his EIS investment, even if no fourth investor were to be found and his shareholding were to exceed 30%
of the issued share capital of Scalar Limited. Does not require the existence of income tax relief in order to be claimed.
Withdrawal of relief:
Any EIS relief claimed by Andrew will be withdrawn (partially or fully) if, within three year of the relevant date:
(1) he disposes of the shares;
(2) he receives value from the company;
(3) he ceases to be a qualifying individual; or
(4) Scalar Limited ceases to be a qualifying company.
With regard to receiving value from the company, the definition excludes dividends which do not exceed a normal rate
of return, but does include the repayment of any loans made to the company before the shares were issued, the provision
of benefits and the purchase of assets from the company at an undervalue. In this regard, Andrew and the other
subscribers should ensure that the ￡50,000 they are to invest in Scalar Limited as loan capital is appropriately timed
and structured relative to the issue of the EIS shares.

正确答案：
(b) (i) UK tax on the rental income
Coral is UK resident in 2007/08 because she is present in the UK for more than 182 days. Accordingly, she will be
subject to UK income tax on her Kalanian rental income.
Coral is ordinarily resident in the UK in 2007/08 as she is habitually resident in the UK.
Coral will have acquired a domicile of origin in Kalania from her father. She has not acquired a domicile of choice in the
UK as she has not severed her ties with Kalania and does not intend to make her permanent home in the UK.
Accordingly, the rental income will be taxed in the UK on the remittance basis.
Any rental income remitted to the UK will fall into the basic rate band and will be subject to income tax at 22% on the
gross amount (before deduction of Kalanian tax). Unilateral double tax relief will be available in respect of the 8% tax
suffered in Kalania such that the effective rate of tax suffered by Coral in the UK on the grossed up amount of income
remitted will be 14%.
In order to minimise the total income tax suffered on the rental income Coral should ensure that it is not brought into or
used in the UK such that it will not be subject to income tax in the UK.
Coral should retain evidence, for example bank statements, to show that the rental income has not been removed from
Kalania. Coral can use the money whilst she is on holiday in Kalania with no UK tax implications.

正确答案：
(b) It is important to appreciate that the finance request should cover not only the cost of the construction of the new facility, but
also costs in order to get the business unit up and running, and enough cash to meet initial working capital requirements.
Mulligan Co may have sufficient cash to cover such additional expenses, but the bank will want comfort that this is the case.
Enquiries would include the following:
Who has prepared the forecast? It is important to evaluate the experience and competence of the preparer. If management
has previously prepared forecasts and capital expenditure budgets that were reliable and accurate, this adds a measure of
confidence in the preparation of the new forecast and the underlying assumptions used.
To what extent is internal finance available to cover any shortfall in the finance requirement? If there is surplus cash within
the organisation then the bank need not provide the full amount of finance necessary to start up the new business operation.
Has the cost of finance been included in the forecast? It appears that this cost is missing. Finance costs should be calculated
based on the anticipated interest rate to be applied to the loan advanced, and included in the total finance requirement.
What is the forecast operating cycle of the new business unit? In particular how long is the work in progress period, and how
much credit will be extended to customers? i.e. when will cash inflows specific to the new business unit be received? More
finance might be required to fund initial working capital shortfalls during the period when work in progress is occurring, and
before cash receipts from customers are received.
Will further raw materials be required? A request has been made for $250,000 for raw materials of timber. Other materials
may need to be purchased, for example, non-timber raw materials, and inventory of other consumables such as nuts and
bolts.
How long will the ‘initial’ inventory of raw material last? What is the planned work in progress time for the new product? More
finance may be needed to avoid a stock out of raw materials.
Construction of the new factory – is there any documentation to support the capital expenditure? For example, architect’s
plans, surveyor’s reports. This will support the accuracy of the finance requested and is an important source of evidence given
the materiality of the premises to the total amount of finance requested.
How likely is it that costs may be subject to inflation before actually being incurred? This could increase the amount of finance
required by several percentage points.
Have quotes been obtained for the new machinery to be purchased?
Purchase of new machinery – will any specific installation costs be incurred? These costs can be significant for large pieces
of capital equipment. Also, enquiries should be made regarding any delivery costs.
The budget does not appear to contain any finance request for overheads such as use of electricity during the construction
period, and hire of installation equipment. Have these overheads been included in the construction cost estimate?
Will staff need to be trained in using the new machinery? If so, any incremental costs should be included in the finance
request.
Advertising and marketing of new product – enquire of Patrick Tiler the methods that will be used to market the new product.
Some types of advertising are more of a cash drain due to their high expense e.g. television advertising is expensive and ‘up
front’ compared to magazine advertising, which is cheap and spread out. As Patrick Tiler is new to Mulligan Co, his forecast
is not based on past experience of this particular business.
LCT Bank will also consider the recoverability of the amount advanced by looking at the cash generating potential of the new
business unit. Enquiries should therefore be made regarding the likely success of the new products, for example:
– Has any market research been carried out to support the commercial viability of the new products?
– Have any contracts with retailers to carry the new products been negotiated?
– How quickly have past products generated a cash inflow?
– Is there a contingency plan in place in case the new products fail to be successful?