2 Graeme, aged 57, is married to Catherine, aged 58. They work as medical consultants, and both are higher rate

taxpayers. Barry, their son, is aged 32. Graeme, Catherine and Barry are all UK resident, ordinarily resident and

domiciled. Graeme has come to you for some tax advice.

Graeme has invested in shares for some time, in particular shares in Thistle Dubh Limited. He informs you of the

following transactions in Thistle Dubh Limited shares:

(i) In December 1986, on the death of his grandmother, he inherited 10,000 ￡1 ordinary shares in Thistle Dubh

Limited, an unquoted UK trading company providing food supplies for sporting events. The probate value of the

shares was 360p per share.

(ii) In March 1992, he took up a rights issue, buying one share for every two held. The price paid for the rights

shares was ￡10 per share.

(iii) In October 1999, the company underwent a reorganisation, and the ordinary shares were split into two new

classes of ordinary share – ‘T’ shares and ‘D’ shares, each with differing rights. Graeme received two ‘T’ and three

‘D’ shares for each original Thistle Dubh Limited share held. The market values for the ‘T’ shares and the ‘D’

shares on the date of reorganisation were 135p and 405p per share respectively.

(iv) On 1 May 2005, Graeme sold 12,000 ‘T’ shares. The market values for the ‘T’ shares and the ‘D’ shares on that

day were 300p and 600p per share respectively.

(v) In October 2005, Graeme sold all of his ‘D’ shares for ￡85,000.

(vi) The current market value of ‘T’ shares is 384p per share. The shares remain unquoted.

Graeme and Catherine have owned a holiday cottage in a remote part of the UK for many years. In recent years, they

have used the property infrequently, as they have taken their holidays abroad and the cottage has been let out as

furnished holiday accommodation.

Graeme and Catherine are now considering selling the UK country cottage and purchasing a holiday villa abroad.

Initially they plan to let this villa out on a furnished basis, but following their anticipated retirement, would expect to

occupy the property for a significant part of the year themselves, possibly moving to live in the villa permanently.

Required:

(a) Calculate the total chargeable gains arising on Graeme’s disposals of ‘T’ and ‘D’ ordinary shares in May and

October 2005 respectively. (7 marks)

(c) Prepare brief notes for the proposed meeting with Charles and Jane. Clearly identify the further information

you would need in order to advise them more fully and suggest appropriate personal financial planning

protection products, in respect of both death and serious illness. (9 marks)

You should assume that the income tax rates and allowances for the tax year 2005/06 and the corporation tax

rates for the financial year 2005 apply throughout this question.

(ii) A proposal which will increase the after tax proceeds from the sale of the Snapper plc loan stock and a

reasoned recommendation of a more appropriate form. of external finance. (3 marks)

(b) Advise Maureen on deregistration for the purposes of value added tax (VAT) and any possible alternative

strategy. (8 marks)

An additional mark will be awarded for the effectiveness with which the information is communicated.

(1 mark)

(ii) Briefly discuss TWO factors which could reduce the rate of return earned by the investment as per the

results in part (a). (4 marks)

(c) Acting as an external consultant to Semer, discuss the validity of the proposed strategy to increase gearing, and explain whether or not the estimates produced in (b) above are likely to be accurate. (10 marks)

(ii) vehicles. (3 marks)

(ii) the strategy of the business regarding its treasury policies. (3 marks)

(Marks will be awarded in part (b) for the identification and discussion of relevant points and for the style. of the

report.)

(d) Explain whether or not Dovedale Ltd, Hira Ltd and Atapo Inc can register as a group for the purposes of value

added tax. (3 marks)

Assume that the corporation tax rates for the financial year 2004 apply throughout.

(b) Explain the corporation tax (CT) and value added tax (VAT) issues that Irroy should be aware of, if she

proceeds with her proposal for the Irish subsidiary, Green Limited. Your answer should clearly identify those

factors which will determine whether or not Green Limited is considered UK resident or Irish resident and

the tax implications of each alternative situation.

You need not repeat points that are common to each situation. (16 marks)

(c) Suggest ways in which each of the six problems chosen in (a) above may be overcome. (6 marks)