案例分析题Hyssop Ltd wishes to provide assistance with home to work travel costs for Corin, who is an employee, and also requires advice on the corporation tax implications of the purchase of a short lease and the value added tax (VAT) implications of the sale of a warehouse. Hyssop Ltd: Is a UK resident trading company. Prepares accounts to 31 December each year. Pays corporation tax at the small profits rate. Is registered for VAT. Leased a factory on 1 February 2015. Corin: Is resident and domiciled in the UK. Is an employee of Hyssop Ltd, who works only at the companys head office. Earns an annual salary of 55,000 from Hyssop Ltd and has no other source of income. Hyssop Ltd assistance with home to work travel costs: Hyssop Ltd is considering two alternatives to provide assistance with Corins home to work travel costs. Alternative 1 provision of a motorcycle: Hyssop Ltd will provide Corin with a leased motorcycle for travelling from home to work. Provision of the leased motorcycle, including fuel, will cost Hyssop Ltd 3,160 per annum. This will give rise to an annual taxable benefit of 3,160 for Corin. Corin will incur no additional travel or parking costs in respect of his home to work travel. Alternative 2 payment towards the cost of driving and provision of parking place: Hyssop Ltd will reimburse Corin for the cost of driving his own car to work up to an amount of 2,240 each year. Corin estimates that his annual cost for driving from home to work is 2,820 Additionally, Hyssop Ltd will pay AB Parking Ltd 920 per year for a car parking space for Corin near the head office. Acquisition of a factory: Hyssop Ltd acquired a 40-year lease on a factory on 1 February 2015 for which it paid a premium of 260,000. The factory is used in Hyssop Ltds trade. Disposal of a warehouse: Hyssop Ltd has agreed to sell a warehouse on 31 December 2015 for 315,000, which will give rise to a chargeable gain of 16,520. Hyssop Ltd had purchased the warehouse when it was newly constructed on 1 January 2012 for 270,000 (excluding VAT). The warehouse was used by Hyssop Ltd in its trade until 31 December 2014, since when it has been rented to an unconnected party. Until 1 January 2015, Hyssop Ltd made only standard-rated supplies for VAT purposes. Hyssop Ltd has not opted to tax the warehouse for VAT purposes. The capital goods scheme for VAT applies to the warehouse. Required: Note: You should ignore value added tax (VAT) for parts (a) and (b).

案例分析题Your firm has been asked to provide advice to two unrelated clients, Stella and Maris. Stella requires advice on the tax implications of making an increased contribution to her personal pension scheme. Maris requires advice regarding the lump sum payment she has received from her pension scheme and the inheritance tax exemptions available on her proposed lifetime gifts. (a) Stella: Is resident and domiciled in the UK. Was born on 1 May 1958. Receives a gross salary of 80,000 each year. Has income from a portfolio of unfurnished properties, totalling 92,000 in the tax year 2015/16. Has no other source of taxable income. Wishes to make an increased contribution to her personal pension scheme in the tax year 2015/16. Personal pension scheme contributions: Stella has contributed 40,000 (gross) to her personal pension scheme in each of the four tax years 2011/12, 2012/13, 2013/14 and 2014/15. Stella wishes to make an increased contribution of 90,000 (gross) in the tax year 2015/16. Required: Calculate Stellas income after tax and pension contributions for the tax year 2015/16 if she does pay 90,000 (gross) into her personal pension scheme. (b) Maris: Is resident and domiciled in the UK and is widowed. Has three married children and five grandchildren under the age of 12. Attained the age of 68 on 30 January 2015 and decided to vest her pension benefits on that date. Wishes to make regular gifts to her family in order to reduce inheritance tax on her death. Personal pension fund: Maris had a money purchase pension scheme which was valued at 1,550,000 on 30 January 2015. Maris took the maximum amount possible as a lump sum on that date. Maris does not understand why the amount she received was 447,500. Assets and income: In addition to pension income and savings income totalling around 60,000, Maris receives dividends from shareholdings in quoted companies of around 45,000 each year. The shareholdings in quoted companies are currently valued at 980,000. Maris wishes to gift some of the shares or the dividend income to her children and grandchildren on their birthdays each year. Maris already makes gifts each year to use her annual exemption for inheritance tax purposes. Required: (i) Explain how the cash of 447,500 received by Maris as a lump sum from her pension scheme was calculated. (ii) Advise Maris of TWO relevant exemptions from inheritance tax which she will be able to use when making the birthday gifts, together with any conditions she will need to comply with in order to obtain them.

案例分析题Acryl Ltd and Cresco Ltd are two unrelated companies. Acryl Ltd requires advice on the implications of being placed into liquidation, particularly the timing of distributions to its shareholders. Cresco Ltd requires advice on the relief for losses on the cessation of trade, and its obligations in relation to value added tax (VAT). (a) Acryl Ltd: Is a UK resident trading company. Has always prepared accounts to 30 June annually. Has substantial distributable profits. 70% of the companys share capital is owned by Mambo Ltd. The remaining 30% of the share capital is owned by Mambo Ltds managing director, Alan. Mambo Ltd and Alan both subscribed for their shares at par value on 1 March 2010. Mambo Ltd: Is a UK resident trading company. Alan: Will be an additional rate taxpayer in the tax year 2016/17. Will be eligible for entrepreneurs relief on the disposal of his shares in Acryl Ltd. Liquidation of Acryl Ltd: Winding up will commence on 1 January 2017 with the appointment of a liquidator. It is anticipated that the winding up will be completed on 31 March 2017, when the company will cease trading. Alternative timing of distributions being considered by Acryl Ltd: Acryl Ltd is prepared to distribute the available profits to its shareholders on 31 December 2016. Alternatively, Acryl Ltd will delay the distribution until the completion of the winding up of the company on 31 March 2017. Required: (i) State the corporation tax consequences arising from the commencement of Acryl Ltds winding up on 1 January 2017. (ii) Explain the tax implications for both Mambo Ltd and Alan if the distribution to be made by Acryl Ltd occurs either on 31 December 2016, or alternatively on 31 March 2017, and conclude as to which date would be preferable. (b) Cresco Ltd: Is a UK resident trading company. Commenced trading on 1 April 2012. Is registered for the purposes of value added tax (VAT). Has made significant trading losses in recent months such that the company will need to cease trading on 31 October 2016. Cresco Ltd trading losses: Recent and anticipated results are as follows: Cresco Ltd always claims relief for trading losses as early as possible. Required: (i) Set out, together with supporting explanations, how Cresco Ltd will claim relief for the trading losses incurred and identify the amount of trading losses which will remain unrelieved after all available loss reliefs have been claimed. (ii) Advise Cresco Ltd of the value added tax (VAT) implications of the cessation of its trade.

案例分析题Max ceased trading two years ago

案例分析题Your manager has had a meeting with Florina and Kanzi who are clients of your firm. Florinas father, Winston, also attended the meeting. The notes prepared following the meeting and an email from your manager setting out the work he requires you to do are set out below. Meeting with Florina, Kanzi and Winston on 6 September 2017 The meeting was attended by Florina and Kanzi (who have been living together since 1999 but are not married) and Winston (Florinas father). All three individuals are resident and domiciled in the UK. They have no sources of income or chargeable gains other than those referred to below. Florina Florina is a director of and shareholder in Flight Hip Ltd. She earns an annual salary of 50,000 and receives a dividend of 20,000 from the company every year. She received total taxable benefits of 25,000 from the company in the tax year 2016/17. Flight Hip Ltd is not a close company Florinas benefits include a company car together with free petrol for both business and private use. The cars benefit percentage by reference to its CO2 emissions is 26%. Florina drives 19,000 miles per year of which 2,000 miles are in the performance of her employment duties. The total cost of all of the petrol used by Florina in the tax year 2016/17 was 3,000. Florinas only other income consists of dividends of 1,500 received in June every year from Landing Properties Ltd. Landing Properties Ltd is an unquoted UK resident company, unrelated to Flight Hip Ltd. Florina purchased 4,000 shares (a holding of less than 1%) in Landing Properties Ltd for 8,000 on 1 August 2001. She is considering selling these shares to Padarn, an unconnected individual, for their market value of 40,000. This would result in a capital gains tax liability of 4,180. I suggested that it may be possible to reduce the tax due by making a gift of some of the shares to Kanzi, who would then sell them to Padarn, and I agreed to provide Florina with further details. Kanzi Kanzi is an artist. His annual taxable trading income is approximately 14,000. Although Kanzi is not employed by Flight Hip Ltd, the company provides him with a car and free petrol. The cars benefit percentage by reference to its CO2 emissions is 23%. Kanzi drives 5,000 miles per year; the total cost of the petrol used by Kanzi in the tax year 2016/17 was 800. Winston Winston is in very poor health and is not expected to live for more than 12 months. It is estimated that Winstons total chargeable estate is currently worth 1,400,000. The values of his assets are not expected to change between now and his death. Winston intends to make a donation of 150,000 to a registered UK charity. This donation will be either a lifetime gift or a legacy from his estate on death. Winstons current will leaves the whole of his estate to Florina and his two other children. Winstons only previous lifetime gift was a chargeable transfer, after the deduction of exemptions, of 200,000 to a trust on 1 June 2015. Winston wants to carry out some sophisticated tax-planning in order to reduce the inheritance tax which will be payable in respect of his death estate. Email from your manager dated 7 September 2017 Please carry out the following work. (a) Florina and Kanzi Florinas remuneration from Flight Hip Ltd Calculate the total tax saving which could be achieved by Florina and Flight Hip Ltd if, in the tax year 2017/18, the company were to make a single lump sum payment of 20,000 into a personal pension fund for Florina instead of paying her a dividend of 20,000. These calculations should take account of the tax which Florina will pay when she eventually withdraws the 20,000 from the pension fund. You should assume that: (1) there will be no further contributions into the fund in future years; and (2) Florina will be a basic rate taxpayer when she makes a withdrawal from the fund. Provision of free petrol By comparing the income tax due in respect of the petrol with the value of the petrol received, determine whether Florina and Kanzi would be better off if: Florina were to reimburse Flight Hip Ltd for the cost of the petrol used by her for private purposes; and/or Flight Hip Ltd were to stop providing Kanzi with free petrol. Sale of shares in Landing Properties Ltd Explain whether or not gift relief would be available in respect of a gift of shares in Landing Properties Ltd from Florina to Kanzi. On the assumption that gift relief would be available, calculate, with supporting explanations, the number of shares which Florina should give to Kanzi, prior to the eventual sale of the shares to Padarn, and the maximum reduction in the total capital gains tax payable which could be achieved. (b) Winstons charitable donation Prepare calculations, with supporting explanations, to show, by reference to inheritance tax only, whether it is more tax-efficient for Winston to make the charitable donation now or via his will. You should ignore the possibility of any further inheritance tax planning taking place. (c) Becoming Winstons tax adviser Winston wants to appoint us to replace his existing tax advisers. Explain any difficulties which we may have complying with the fundamental principles of professional ethics in relation to acting for Winston and suggest appropriate safeguards. Tax manager Required: Carry out the work requested in the email from your manager. The following marks are available:

案例分析题Jordi is a director and shareholder of Traiste Ltd. He has asked for your advice in connection with the forthcoming redundancy of an employee, the sale of shares in Traiste Ltd by his sister, Kat, and the payment implications for Traiste Ltd of alternative ways for Jordi to extract profits from the company. Traiste Ltd: Is a UK resident unquoted trading company. Has two shareholders, Jordi and Kat, who each own 50% of the 1,000 1 shares in issue. Traiste Ltd proposed redundancy package for an employee: An employee, Esta, will be made redundant on 30 June 2017. Esta will receive statutory redundancy pay of 12,000 and an ex-gratia payment of 36,000 from Traiste Ltd. Traiste Ltd will continue to lease a motor car for Estas personal use until 31 December 2017, although she has no contractual entitlement to this. The monthly lease payments are 420. The motor car has CO2 emissions of 178 grams per kilometre and is petrol powered. The motor car is currently worth 10,300. Its list price when new was 18,400. Kat: Is resident and domiciled in the UK. Is 58 years old. Is a director and shareholder of Traiste Ltd. Will receive employment income of 34,000 from Traiste Ltd and dividends from other UK companies of 4,000 in the tax year 2017/18. Has already used her annual exempt amount for capital gains tax purposes for the tax year 2017/18. Kat proposed sale of shares: Kat subscribed for her 500 shares in Traiste Ltd at par on the incorporation of the company on 1 March 2013. She wishes to sell all of her shares before the end of 2017, and retire from the company. Kats brother, Jordi, has offered to buy these shares for 47 each. He is not prepared to sign any tax election in relation to this offer. Alternatively, Traiste Ltd will buy these shares for their market value of 52 each. Jordi: Is resident and domiciled in the UK. Is 53 years old. Is a director and shareholder of Traiste Ltd. Is paid a gross annual salary of 50,000 by Traiste Ltd. Wishes to extract an additional cash sum of 30,000, net of all taxes, from Traiste Ltd, to be paid on 31 March 2018. The additional sum will be extracted as either a bonus or a dividend. Will not receive any other taxable income in the tax year 2017/18. Required:

案例分析题Your manager has sent you a memorandum in relation to the Harrow Tan Ltd group. An extract from the memorandum and a schedule of group information prepared by Corella, the group finance director, are set out below. Memorandum from your manager dated 7 September 2017 Background We are advising Corella, the group finance director, on a number of matters. Ive attached a schedule from Corella, which sets out much of the relevant information. Corella was only recently appointed the Harrow Tan Ltd group finance director. She has had very little experience of practical tax since qualifying as an accountant in 1994. I have carried out a brief review of Corellas schedule and concluded that it is mathematically correct but that we cannot rely on its tax technical content. All five group companies are UK resident trading companies which prepare accounts to 31 December each year. Sale of shares in Rocha Ltd Harrow Tan Ltd acquired the whole of the ordinary share capital of Rocha Ltd (100,000 shares) on 1 December 2016 for 8,900,000. On 1 January 2017, Seckel Ltd (owned 80% by Harrow Tan Ltd) sold a commercial building to Rocha Ltd for 800,000, its market value on that date. The group claimed exemption from stamp duty land tax in respect of this transaction. Seckel Ltd had purchased the building on 1 May 1998 at a cost of 330,000. However, the results of Rocha Ltd for the year ending 31 December 2017 are now expected to be significantly worse than originally budgeted and an agreement was signed on 31 July 2017 for Harrow Tan Ltd to sell 60,000 Rocha Ltd ordinary shares for 10,300,000. It is planned that the sale of these shares will take place on 1 October 2017, although the sale could be delayed by up to three months if necessary。 Tosca Ltd promotion of new product Tosca Ltd manufactures high quality glass bowls. It accounts for value added tax (VAT) using the annual accounting scheme. Tosca Ltd has developed a new product, which is expected to increase the companys annual turnover from 1,200,000 to 2,000,000. The new product is to be marketed to the companys customers, all of whom are UK based retailers, via promotional evenings in various parts of the UK. At the promotional evenings the retailers will be provided with a meal. They will also be given a sample of the new product costing approximately 90, and a pen costing 40. Please prepare notes for us to use in a meeting with Corella, which EXPLAIN the following matters: (i) Sale of shares in Rocha Ltd The error(s) and omission(s) in part A of Corellas schedule together with any tax saving opportunities or other matters, including stamp duty land tax, which are not addressed in part A of her schedule. Please include a corrected calculation of the taxable gain on the sale on the assumption that it occurs on 1 October 2017. Take some time to think about this. From my brief review I think there may be three or four issues which need to be brought to Corellas attention. (ii) Group relief year ending 31 December 2017 By reference to the information in part B of Corellas schedule, the maximum amount of Seckel Ltds trading loss which can be surrendered to each of the other companies in the Harrow Tan Ltd group. (iii) Rollover relief The rollover relief potentially available to the group and the accuracy of part C of Corellas schedule. Memorandum from your manager dated 7 September 2017 (continued) (iv) Tosca Ltd promotion of new product The VAT implications of: the expected increase in the turnover of Tosca Ltd; and the entertainment and gifts at the promotional evenings. Schedule of group information from Corella, the group finance director Notes: 1. Disposal of shares in Rocha Ltd. 2. Uta Far Ltd sold a building used in its business on 1 May 2017 for 1,800,000. This resulted in a chargeable gain of 85,000. C: Harrow Tan Ltd Acquisitions in the year ending 31 December 2017 qualifying for rollover relief Required: Prepare the meeting notes as requested by your manager. The following marks are available:

案例分析题Your manager has had a meeting with Wanda

案例分析题Your manager has sent you an email

案例分析题Adam would like advice on the capital gains tax and inheritance tax implications of being given Eastwick Farm by his mother, Sabrina, and on recent changes in tax law which affect his investment planning

案例分析题The finance director of Achiote Ltd would like your advice on the tax implications of the acquisition of two intangible fixed assets, various transactions involving an overseas subsidiary, and opting to tax a commercial building. Achiote Ltd: Owns 100% of the ordinary shares in Borage Ltd and 80% of the ordinary shares in Caraway Inc. Achiote Ltd and Borage Ltd are resident in the UK. Caraway Inc is resident in the country of Nuxabar. All three companies are trading companies and prepare accounts to 31 March annually. Borage Ltd purchase of intangible fixed assets: Borage Ltd purchased the goodwill of an unincorporated business for 62,000 on 1 September 2016. Borage Ltd will amortise this goodwill in its accounts on a straight-line basis over a five-year period. Borage Ltd also purchased a patent from Achiote Ltd for 45,000 on 1 January 2017. Achiote Ltd had purchased the patent for 38,000 on 1 January 2014. The patent was being amortised in Achiote Ltds accounts on a straight-line basis over a ten-year period. Borage Ltd will continue to amortise the patent over the remainder of its ten-year life. Achiote Ltd loan to Caraway Inc: Achiote Ltd made a loan of 100,000 to Caraway Inc on 1 April 2016. The rate of interest on the loan is 6% per annum, which is 2% below the rate applicable to an equivalent loan from an unrelated party. There is no double tax treaty between the UK and Nuxabar Achiote Ltd sale of equipment to, and proposed sale of shares in, Caraway Inc: Achiote Ltd acquired its 80% shareholding in Caraway Inc on 1 January 2017 for 258,000. Achiote Ltd is now proposing to sell an 8% shareholding in Caraway Inc to an unconnected company on 1 October 2017 for 66,000. An item of equipment owned by Achiote Ltd and used in its trade was sold to Caraway Inc on 1 March 2017 for its market value of 21,000. The item of equipment had cost Achiote Ltd 32,000 in May 2016. Achiote Ltd purchase and rental of a commercial building: Achiote Ltd has recently purchased a two-year-old commercial building from an unconnected vendor. The building will be rented to an unconnected company, Rye Ltd. Rye Ltd is a small local company, which supplies goods to Achiote Ltd but does not charge value added tax (VAT) on these sales. Required:

案例分析题Your client, Eric

案例分析题Meg is an unincorporated sole trader

案例分析题Juanita has contacted you following the death of her husband, Don. As the executor of his estate, she is seeking advice regarding the inheritance tax liability arising as a result of his death on shares which he owned. She also requires advice on the timing of her ceasing to trade. Don: Died on 1 July 2016. Had always been UK resident and domiciled. Was married to Juanita, and they have one daughter, Lexi. Lifetime gifts: Don made only two lifetime gifts. On 9 May 2011, Don gifted his overseas villa to Lexi. The villa was valued at 355,000 on 9 May 2011, and at 370,000 on 1 July 2016. On 1 March 2013, on the advice of a financial adviser, Don gifted 3,500 of his shares in Estar Ltd to Lexi. Prior to receiving this advice, Don had been planning to leave these shares to Lexi on his death. Under the terms of Dons will, Dons cousin will inherit the remaining 3,500 shares in Estar Ltd owned by Don at his death. Estar Ltd: Is an investment company; no business property relief is available on the transfer of its shares. Before the gift on 1 March 2013, Don owned 7,000 ordinary shares in Estar Ltd. The remaining 3,000 ordinary shares issued by Estar Ltd are held by Juanita. The shares were valued as follows: Percentage shareholding Value per share 1 March 2013 1 July 2016 0%50% 900 1080 51%75% 1500 1800 76%100% 2000 2400 Juanita: Has carried on a business as a sole trader for many years, preparing accounts to 30 June annually. Following Dons death, intends to cease trading and retire. Would like to cease trading on 28 February 2017, in which case the business will be sold to an unconnected person. Is willing to continue to trade until 30 April 2017, when Lexi will be able to take over the business. Does not anticipate having any other source of taxable income in either of the tax years 2016/17 or 2017/18. Juanitas business: Has taxable trading profits of 51,000 for the year ended 30 June 2016. Has budgeted tax-adjusted profits of 48,000 (before capital allowances) in the period ending 28 February 2017. Has budgeted further taxable profits of 4,000 per month if Juanita continues to trade after 28 February 2017. Has overlap profits from commencement of 17,000. The tax written down value on the main pool was nil at 1 July 2016. The market value of the assets in the main pool will be 6,000 at the date of cessation. Required:

案例分析题Your manager has had a meeting with Jonny who is establishing a new business. An extract from an email from your manager, a schedule and a computation are set out below. Extract from the email from your manager Jonny was born in 1968. His new business will begin trading on 1 November 2015. Jonny will use an inheritance he received following the death of his mother to finance this new venture. We have been asked to advise Jonny on his business and his inheritance. Some of the work has already been done; I want you to complete it. Please prepare a memorandum for Jonnys client file addressing the following issues: (a) Unincorporated business I attach a schedule which sets out Jonnys recent employment income and his plans for the new business. I think you will find it useful to read the schedule before you go through the rest of this email. You should assume that Jonny does not have any other sources of income or any taxable gains in any of the relevant tax years. (i) Jonnys post-tax income Jonny has asked for an approximation of his post-tax income position for the first two trading periods. I want you to prepare calculations in order to complete the following table, assuming that any available trading loss reliefs will be claimed in the most beneficial manner. You should include explanations of the options available to relieve the loss, clearly identifying the method which will maximise the tax saved (you do not need to consider carrying the loss forward). Table to be completed Include a brief explanation as to why these calculations are only an approximation of Jonnys budgeted post-tax income. (ii) Salesmen Jonny intends to hire two salesmen to get the business started. Their proposed contractual arrangements are as set out in the attached schedule. Explain which of the proposed contractual arrangements with the salesmen indicate that they would be self-employed and state any changes which should be made to the other arrangements in order to maximise the likelihood of the salesmen being treated as self-employed. (iii) New contracts for the business Jonny is hoping to obtain contracts with local educational establishments and has asked us to help. One of our clients is a college and an ex-client of ours provided services to a number of schools and colleges. Accordingly, we have knowledge and experience in this area. Explain the extent to which it is acceptable for us to use the knowledge we have gained in respect of our existing client and ex-client to assist Jonny. (b) Jonnys inheritance from his mother Jonnys mother died on 31 July 2015. She left the whole of her estate, with the exception of a gift to charity, to Jonny. I attach a computation of the inheritance tax due; this was prepared by a junior member of staff and has not yet been reviewed. I can confirm, however, that all of the arithmetic, dates and valuations are correct. In addition, there were no other lifetime gifts, and none of the assets qualified for business property relief. I want you to review the computation and identify any errors. You should explain each of the errors you find and calculate the value of the inheritance which Jonny will receive after inheritance tax has been paid. Tax manager Schedule Employment income and plans for the new business Jonnys income Jonny worked full-time for many years until 30 June 2013 earning a salary of 6,000 per calendar month. From 1 July 2013, he worked part-time earning a salary of 2,000 per calendar month until he ceased employment on 31 March 2015. Two budgets have been prepared for Jonnys business based on customer demand being either strong or weak. You should assume that no tax adjustments are required to Jonnys budgeted profit/loss figures for the first two trading periods. For strong demand, the taxable trading profit for the first two tax years has been computed; these figures are correct and you do not need to check them. You will, however, need to calculate the equivalent figures for weak demand. Salesmen Jonny is proposing to enter into the following contractual arrangements with two part-time salesmen: They will work on Tuesday and Wednesday mornings each week for a two-month period. They will be paid a fee of 300 for each new sales contract obtained. No other payments will be made. They will use their own cars. Jonny will lend each of them a laptop computer. Computation Inheritance tax payable on the death of Jonnys mother Required: Prepare the memorandum as requested in the email from your manager. The following marks are available:

案例分析题Your firm has been asked to provide advice to Granada Ltd, and one of its shareholders, Maria

案例分析题Your manager has been advising a client, Waverley

案例分析题Demeter has recently taken up a new employment and is seeking advice on the tax treatment of certain components of his remuneration package, and the relief(s) available to reduce the chargeable gain on the sale of his house. Demeter: Is UK resident and domiciled. Commenced employment with Poseidon Ltd on 1 December 2018. Will have no source of income, other than from Poseidon Ltd, in all relevant future tax years. Will be a higher rate taxpayer in all relevant future tax years. Has relocated to London, from Manchester, a city more than 150 miles north of London, to take up this employment. Remuneration package from Poseidon Ltd: Demeter will receive an annual salary of 130,000. On 1 December 2018, Poseidon Ltd made a one-off lump sum payment of 20,000 to Demeter as an inducement to take up employment with the company. Poseidon Ltd paid Demeter 5,000 towards his costs of relocating to London. The company is also paying him 1,500 each month for four months from 1 December 2018 towards renting accommodation in London until he purchases a new house on 1 April 2019. On 1 December 2018, Demeter was granted share options in Poseidon Ltds unapproved share option scheme. From 6 April 2019, Demeter will participate in Poseidon Ltds approved occupational pension scheme. Relocation to London: Demeter incurred costs in relation to his relocation to London of 6,000. This amount includes estate agent fees of 2,800 in connection with the sale of his house in Manchester on 31 October 2018. Demeter signed a four-month lease for a flat in London from 1 December 2018 at a monthly rental of 1,700. House in Manchester: Demeter purchased the house on 1 May 2005 and lived in it as his main residence. Demeter let the top floor of the house (comprising 30% of the total house) to tenants from 1 May 2007 to 31 October 2018. The tenants did not share Demeters living accommodation or take meals with him. Demeter continued to occupy the remainder of the house as his main residence until 31 October 2018, when the entire house was sold. The sale gave rise to a gain, before any reliefs, of 94,000. Demeter did not own any other house throughout the period from 1 May 2005 to 31 October 2018. Demeter pension contributions: Demeter has made tax-allowable contributions of 40,000 (gross) to a personal pension plan for the last five tax years and will continue to do so in future tax years. From the tax year 2019/20, Poseidon Ltd will contribute an amount equal to 10% of Demeters annual salary to its approved occupational pension scheme. Demeter will make no contributions to Poseidon Ltds occupational pension scheme. Poseidon Ltds share option scheme: On 1 December 2018, Poseidon Ltd granted Demeter options over 3,000 shares in its unapproved share option scheme at a 5% discount on the market value of the shares on that date. The market value of Poseidon Ltd shares on 1 December 2018 was 420 per share. Demeter will exercise the options on 6 April 2024, and immediately sell the shares. Poseidon Ltd believes that the market value of its shares on 6 April 2024 will be 600 per share. Required:

案例分析题Your manager has received a letter from Christina

案例分析题 Your manager has asked you to take charge of some work in connection with the Heyer Ltd group of companies. A schedule of information from the client files and an email from your manager detailing the work he requires you to do are set out below Heyer Ltd group schedule of information from the client files Group structure General information All of the companies are resident in the UK and prepare accounts to 31 December each year. The figures given below of taxable total profits (TTP) take account of all possible rollover relief claims. None of the companies has received any dividend income from non-group companies. Specific information Mantet Ltd Mantet Ltd has TTP of between 40,000 and 50,000 every year. Newell Rap Ltd Heyer Ltd acquired Newell Rap Ltd on 1 May 2016. Newell Rap Ltd has a capital loss brought forward as at 1 January 2017 of 94,000. This loss arose on a sale of land on 1 February 2014. Orin Hod Ltd The TTP of Orin Hod Ltd exceed 200,000 every year. In the year ending 31 December 2017 Orin Hod Ltd will make chargeable gains of 86,000. Other 100% owned companies Each of these companies has TTP of more than 130,000 every year. Four of them will have substantial chargeable gains in the year ending 31 December 2017. Five of them will have capital losses in the year ending 31 December 2017. Heyer Ltd group schedule of information from the client files (continued) Group restructuring It is intended that the trade and assets of five group companies (Newell Rap Ltd and four of the other 100% owned companies) will be sold to Lodi Ltd at some point in January 2018. The assets of the five companies, including the business premises, machinery and equipment will be sold to Lodi Ltd for their market value. The tax written down value of the main pool of each of the five companies immediately prior to the sale will be zero. Pink Time Ltd Heyer Ltd intends to incorporate a new subsidiary, Pink Time Ltd, on 1 September 2017. Pink Time Ltd will have a monthly turnover of 35,000. All of its sales will be to members of the public and will be zero rated for the purposes of value added tax (VAT). Email from your manager dated 8 June 2017 Please carry out the following work: (a) Group planning The groups objective is to minimise the corporation tax payable in instalments by group companies in respect of the year ended 31 December 2017. I have asked Cox, our tax assistant, to carry out this work and I have provided him with the details of the companies budgeted results for 2017. There is no group relief available within the group. Cox has not done this type of work before and he has had very little experience of capital gains groups, so I want you to prepare some guidance for him. The guidance should consist of explanations of: the circumstances in which a member of the Heyer Ltd group would be required to pay corporation tax in instalments, assuming that the profits threshold should be divided by 18; which companies are members of a capital gains group; how Cox should determine the amount of chargeable gains and capital losses to transfer between the group companies in order to achieve the groups objective; and the relevance to the groups objective of the specific information provided in the schedule of information. (b) Group restructuring Identify, with reasons, the implications of the proposed group restructuring in relation to chargeable gains, stamp duty land tax and capital allowances, and what will happen to any capital losses belonging to the five companies whose trade and assets are transferred. (c) Pink Time Ltd Explain whether it will be compulsory for Pink Time Ltd to register for value added tax (VAT) and why the company would benefit from registering. (d) Disclosure of transfer pricing It has been realised by the management of Heyer Ltd that transfer pricing adjustments should have been made in respect of the year ended 31 December 2013 for three of the companies in the group. The corporation tax liability of the group was understated as a result of this non-disclosure. I have already explained the interest and penalties which may be charged in respect of this. I want you to list the other matters which need to be considered, by us, as tax advisers to the group, and by the management of the group, in relation to the disclosure or non-disclosure of this information to HM Revenue and Customs (HMRC). Tax manager Required: Carry out the work requested in the email from your manager. The following marks are available: