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(ii) Two factors which might reduce the return earned by the investment are as follows:
(i) Poor product quality
The very nature of the product requires that it is of the highest quality i.e. the cakes are made for human
consumption. Bad publicity via a ‘product recall’ could potentially have a catastrophic effect on the total sales to
Superstores plc over the eighteen month period.
(ii) The popularity of the Mighty Ben character
There is always the risk that the popularity of the character upon which the product is based will diminish with a
resultant impact on sales volumes achieved. In this regard it would be advisable to attempt to negotiate with
Superstores plc in order to minimise potential future losses.

正确答案：
(d) UK tax implications of shares in Bubble Inc
Income tax
Gloria is UK resident and is therefore subject to income tax on her worldwide income. However, because she is non-UK
domiciled, she will only be taxed on the foreign dividends she brings into the UK.
Dividends brought into the UK will be grossed up for any tax paid in Oceania. The gross amount is taxed at 10% if it falls
into the starting or basic rate band and at 321/2% if it falls into the higher rate band. The tax suffered in Oceania is available
for offset against the UK tax liability. The offset is restricted to a maximum of the UK tax on the dividend income.
Capital gains tax
Individuals are subject to capital gains tax on worldwide assets if they are resident or ordinarily resident in the UK. However,
because Gloria is non-UK domiciled and the shares are situated abroad, the gain is only taxable to the extent that the sales
proceeds are brought into the UK. Any tax suffered in Oceania in respect of the gain is available for offset against the UK
capital gains tax liability arising on the shares.
Any loss arising on the disposal of the shares would not be available for relief in the UK.
In computing a capital gain or allowable loss, a deduction is available for the incidental costs of acquisition. However, to be
allowable, such costs must be incurred wholly and exclusively for the purposes of acquiring the asset. The fee paid to Eric
related to general investment advice and not to the acquisition of the shares and therefore, would not be deductible in
computing the gain.
Taper relief will be at non-business asset rates as Bubble Inc is an investment company.
Inheritance tax
Assets situated abroad owned by non-UK domiciled individuals are excluded property for the purposes of inheritance tax.
However, Gloria will be deemed to be UK domiciled (for the purposes of inheritance tax only) if she has been resident in the
UK for 17 out of the 20 tax years ending with the year in which the disposal occurs.
Gloria has been running a business in the UK since June 1992 and would therefore, appear to have been resident for at least
15 tax years (1992/93 to 2006/07 inclusive).
If Gloria is deemed to be UK domiciled such that the shares in Bubble Inc are not excluded property, business property relief
will not be available because Bubble Inc is an investment company.

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(d) Repayment of the loan
If at the beginning of the loan agreement, it was expected that the repayment option would not be exercised, then the effective
interest rate would be 8% and at 30 April 2008, the loan would be stated at $2 million in the statement of financial position
with interest of $160,000 having been paid and accounted for. If, however, at 1 May 2007, the option was expected to be
exercised, then the effective interest rate would be 9·1% and at 30 April 2008, the cash interest paid would have been
$160,000 and the interest charged to the income statement would have been (9·1% x $2 million) $182,000, giving a
statement of financial position figure of $2,022,000 for the amount of the financial liability. However, IAS39 requires the
carrying amount of the financial instrument to be adjusted to reflect actual and revised estimated cash flows. Thus, even if
the option was not expected to be exercised at the outset but at a later date exercise became likely, then the carrying amount
would be revised so that it represented the expected future cash flows using the effective interest rate. As regards the
discussions with the bank over repayment in the next financial year, if the loan was shown as current, then the requirements
of IAS1 ‘Presentation of Financial Statements’ would not be met. Sirus has an unconditional right to defer settlement for longer
than twelve months and the liability is not due to be legally settled in 12 months. Sirus’s discussions should not be considered
when determining the loan’s classification.
It is hoped that the above report clarifies matters.

正确答案：
(ii) Damian should not agree to the sales director’s suggestion. The salesmen will each make a significant annual income
tax saving under the proposal, whereas the company will also be offset (at least partly) by the reduction in the dealer’s
bulk discount. Further, 100% first year allowance tax incentive for low emission cars is not guaranteed beyond 31 March
2008, and it is unlikely that any change in policy with regards to the provision of additional accessories will, once
implemented, be easily reversible.