我今年29岁，目前报了ACCA考试，听说这个考...

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：

3 ALBREDA CO

(a) Cessation of ‘home delivery’ service
(i) Matters
■ $0·6 million represents 1·4% of reported revenue (prior year 1·9%) and is therefore material.
Tutorial note: However, it is clearly not of such significance that it should raise any doubts whatsoever regarding
the going concern assumption. (On the contrary, as revenue from this service has declined since last year.)
■ The home delivery service is not a component of Albreda and its cessation does not classify as a discontinued
operation (IFRS 5 ‘Non-current Assets Held for Sale and Discontinued Operations’).
? It is not a cash-generating unit because home delivery revenues are not independent of other revenues
generated by the restaurant kitchens.
? 1·4% of revenue is not a ‘major line of business’.
? Home delivery does not cover a separate geographical area (but many areas around the numerous
restaurants).
■ The redundancy provision of $0·2 million represents 11·1% of profit before tax (10% before allowing for the
provision) and is therefore material. However, it represents only 0·6% of total assets and is therefore immaterial
to the balance sheet.
■ As the provision is a liability it should have been tested primarily for understatement (completeness).
■ The delivery vehicles should be classified as held for sale if their carrying amount will be recovered principally
through a sale transaction rather than through continuing use. For this to be the case the following IFRS 5 criteria
must be met:
? the vehicles must be available for immediate sale in their present condition; and
? their sale must be highly probable.
Tutorial note: Highly probable = management commitment to a plan + initiation of plan to locate buyer(s) +
active marketing + completion expected in a year.
■ However, even if the classification as held for sale is appropriate the measurement basis is incorrect.
■ Non-current assets classified as held for sale should be carried at the lower of carrying amount and fair value less
costs to sell.
■ It is incorrect that the vehicles are being measured at fair value less costs to sell which is $0·3 million in excess
of the carrying amount. This amounts to a revaluation. Wherever the credit entry is (equity or income statement)
it should be reversed. $0·3 million represents just less than 1% of assets (16·7% of profit if the credit is to the
income statement).
■ Comparison of fair value less costs to sell against carrying amount should have been made on an item by item
basis (and not on their totals).
(ii) Audit evidence
■ Copy of board minute documenting management’s decision to cease home deliveries (and any press
releases/internal memoranda to staff).
■ An analysis of revenue (e.g. extracted from management accounts) showing the amount attributed to home delivery
sales.
■ Redundancy terms for drivers as set out in their contracts of employment.
■ A ‘proof in total’ for the reasonableness/completeness of the redundancy provision (e.g. number of drivers × sum
of years employed × payment per year of service).
■ A schedule of depreciated cost of delivery vehicles extracted from the non-current asset register.
■ Checking of fair values on a sample basis to second hand market prices (as published/advertised in used vehicle
guides).
■ After-date net sale proceeds from sale of vehicles and comparison of proceeds against estimated fair values.
■ Physical inspection of condition of unsold vehicles.
■ Separate disclosure of the held for sale assets on the face of the balance sheet or in the notes.
■ Assets classified as held for sale (and other disposals) shown in the reconciliation of carrying amount at the
beginning and end of the period.
■ Additional descriptions in the notes of:
? the non-current assets; and
? the facts and circumstances leading to the sale/disposal (i.e. cessation of home delivery service).

正确答案：
(ii) On the other hand, the job description is based on information gathered from a job analysis and defines the position and role
that has to be fulfilled. It is a statement of the component tasks, duties, objectives and standards. It describes the purpose
and relationships of the specific job together with the physical, social and economic factors which affect it. Fundamentally, it
describes the job to be done.

正确答案：
(a) A highly-geared company has an obligation to pay interest on its loans regardless of its profit level. It will show high profits if
its overall rate of return on capital is greater than the rate of interest being paid on its borrowings, but a low profit or a loss if
there is a down-turn in its profit such that the rate of interest to be paid exceeds the return on its assets.