1、ACCA 考试 P6 高级税务（United+Kingdom）真题 2015 年 6 月及答案解析(总分：120.02，做题时间：180 分钟)一、SUPPLEMENTARY INSTRU(总题数：1，分数：0.00)1.1.Your manager has received a letter from Jodie in connection with her proposed emigration from the UK. Extracts from the letter and from an email from your manager are set out below. Extra
2、ct from the letter from Jodie Extract from an email from your manager (a) UK tax residence status and liability to UK income tax. (7 marks) (b) Relief available in respect of the trading loss. (8 marks) (c) Capital gains tax. (11 marks) (d) Other matters. (5 marks) Professional marks will be awarded
3、 for following the managers instructions, the clarity of the explanations and calculations, the effectiveness with which the information is communicated, and the overall presentation.(4 marks) Notes 1. You should assume that the tax rates and allowances for the tax year 2014/15 apply to all tax year
4、s. 2. Ignore national insurance contributions throughout this question. (35 marks)（分数：35.00）_2.Your manager has had a number of telephone conversations with Gomez, a potential new client. Gomez owns the whole of the ordinary share capital of Helm Ltd. Extracts from the memorandum prepared by your ma
5、nager setting out the matters discussed and an email from your manager in connection with the Helm Ltd group are set out below. Extracts from the memorandum Email from your manager （分数：25.00）(1).(a) Sale of Bar Ltd. (11 marks) Note: The following figures from the Retail Prices Index should be used,
6、where necessary. July 1994 1440 October 2013 2519 December 2013 2534 April 2014 2557（分数：6.25）_(2).(b) Drill Ltd.（分数：6.25）_(3).(c) Cog Ltd chargeable gain on the sale of the warehouse.（分数：6.25）_(4).(d) Becoming tax advisers to Gomez and the Helm Ltd group of companies. (5 marks) （分数：6.25）_三、Section B
7、 TWO ques(总题数：3，分数：60.00)3.Nocturne Ltd, a partially exempt company for the purposes of value added tax (VAT), requires advice on the corporation tax implications of providing an asset to one of its shareholders; the income tax implications for another shareholder of making a loan to the company; an
8、d simplifying the way in which it accounts for VAT. Nocturne Ltd: Is a UK resident trading company. Prepares accounts to 31 March annually and expects to pay corporation tax at the rate of 20%. Has four shareholders, each of whom owns 25% of the companys ordinary share capital. Owns a laptop compute
9、r, which it purchased in October 2012 for 1,200, and which has a current market value of 150. Has purchased no other plant and machinery for several years and the tax written down value of its main pool at 31 March 2015 was nil. Provision of a laptop computer to one of Nocturne Ltds shareholders: No
10、cturne Ltd is considering two alternative ways of providing a laptop computer in the year ending 31 March 2016 for the personal use of one of its shareholders, Jed. Jed is neither a director nor an employee of Nocturne Ltd. Option1: Nocturne Ltd will buy a new laptop computer for 1,800 and give it i
11、mmediately to Jed. Option 2: Nocturne Ltd will gift its existing laptop to Jed and will purchase a replacement for use in the company for 1,800. Loan from Siglio: Siglio will loan 60,000 to Nocturne Ltd on 1 October 2015 to facilitate the purchase of new equipment. Siglio is both a shareholder of No
12、cturne Ltd and the companys managing director. Nocturne Ltd will pay interest at a commercial rate on the loan from Siglio. Siglio will borrow the full amount of the loan from his bank on normal commercial terms. VAT partial exemption: Nocturne Ltd is partially exempt for the purposes of VAT. Noctur
13、ne Ltds turnover for the year ended 31 March 2015 was 240,000 (VAT exclusive). Nocturne Ltds turnover for the year as a whole for VAT purposes comprised 86% taxable supplies and 14% exempt supplies. The input VAT suffered by Nocturne Ltd on expenditure during the year ended 31 March 2015 was: （分数：20
14、.01）(1).(a) Explain, with the aid of supporting calculations, which of the two proposed methods of providing the laptop computer to Jed would result in the lower after-tax cost for Nocturne Ltd. Note: You should ignore value added tax (VAT) for part (a) of this question. (7 marks)（分数：6.67）_(2).(b) E
15、xplain the income tax implications for Siglio of providing the loan to Nocturne Ltd. (4 marks)（分数：6.67）_(3).(c) (i) Determine, by reference to the de minimis tests 1 and 2, Nocturne Ltds recoverable input VAT for the year ended 31 March 2015. (4 marks) (ii) Advise Siglio of Nocturne Ltds eligibility
16、 for the annual test for computing the amount of recoverable input VAT for the year ending 31 March 2016 and the potential benefits to be gained from its use.(5 marks)（分数：6.67）_4.King, a wealthy client of your firm with a significant property portfolio, requires advice on the sale of some unquoted s
17、hares and on the capital gains tax and inheritance tax implications of transferring assets to a trust and to his two children. King: Is resident and domiciled in the UK. Is an additional rate taxpayer. Has used his capital gains tax annual exempt amount for the tax year 2015/16. Has made one previou
18、s lifetime gift of 25,000 to his daughter, Florentyna, on 1 June 2014. It should be assumed that King will die on 1 May 2017. Kings family: Kings daughter, Florentyna, is 34 years old and has two young children. Florentyna will have income from part-time employment of 10,000 in the tax year 2015/16.
19、 This is her only source of taxable income. Kings son, Axel, is 40 years old and has an 18-year-old daughter, who is a university student. Kings plans: On 1 September 2015, King will sell some of his shares in Wye Ltd. On 1 October 2015, King will put a cottage he owns in Newtown and the after-tax c
20、ash proceeds from the sale of the shares in Wye Ltd into an interest in possession trust for Florentyna and her children. On 1 March 2016, King will gift his share of a flat in Unicity to Axel. Sale of shares in Wye Ltd: Wye Ltd is an unquoted investment company. King acquired 5,000 shares in Wye Lt
21、d on 1 June 2002 at a cost of 5 each. These shares will be worth 45 each on 1 September 2015. King will sell sufficient shares to generate after-tax proceeds of 30,000. Cottage in Newtown: This property is wholly owned by King. It is expected to have a value of 315,000 on 1 October 2015. Creation of
22、 the interest in possession trust: King will pay any inheritance tax arising as a result of the gifts made to the trust. Florentyna will be the life tenant and her two young children will be the remaindermen of the trust. Florentyna will live in the cottage in Newtown and the trustees will invest th
23、e cash in quoted shares which will generate annual dividends of 3,000. Flat in Unicity: The flat in Unicity is jointly owned by King and his wife, Joy, in the proportions: King 75% and Joy 25%. King and Joy have recently signed a contract with Axels daughter to rent the flat to her for three years s
24、tarting on 1 September 2015. The rental agreement is on a commercial basis. King has obtained the following expected valuations for the flat as at 1 March 2016 （分数：20.00）(1).(a) Calculate the minimum number of shares in Wye Ltd which King must sell to generate after-tax proceeds of 30,000. (3 marks)
25、（分数：5.00）_(2).(b) (i) Advise King, with the aid of supporting calculations, of the capital gains tax and immediate inheritance tax implications of the proposed gift of assets into the interest in possession trust on 1 October 2015.(6 marks)（分数：5.00）_(3).(ii) Explain how Florentyna will be taxed on t
26、he income arising in the trust and calculate the additional income tax, if any, payable by her in respect of this income for the tax year 2015/16. (4 marks)（分数：5.00）_(4).(c) Explain, with the aid of supporting calculations, why the disposal of the flat in Unicity may be caught by the associated oper
27、ations rules and the increase in the inheritance tax liability which would arise on Kings death on 1 May 2017 if these rules were to apply. (7 marks)（分数：5.00）_5.Cate requires advice on the after-tax cost of taking on a part-time employee and the tax implications of starting to sell items via the int
28、ernet. Cates husband, Ravi, requires advice in relation to capital gains tax on the disposal of an overseas asset. Cate: Is resident and domiciled in the UK. She is aged 48. Is married to Ravi. Runs a successful unincorporated business, D-Designs. Receives dividends of 27,000 each year. Wants to sel
29、l some second-hand books online. D-Designs business: Was set up by Cate in 2008. Is now making a taxable profit of 90,000 per annum. Operates a number of dress shops and already employs six full-time staff. Requires an additional part-time employee. Part-time employee proposed remuneration package:
30、Salary of 12,000 per annum. Qualifying childcare vouchers of 25 per week for 52 weeks a year. Mileage allowance of 50 pence per mile for the 62-mile round trip required each week to redistribute stock between the shops. This will be for 48 weeks in the year. This employment will be the employees onl
31、y source of taxable income. Sale of second-hand books: Cate inherited a collection of books from her mother in December 2013. Cate intends to sell these books via the internet. Some of the books are in a damaged state and Cate will get them rebound before selling them. Ravi: Is domiciled in the coun
32、try of Goland. Has been resident in the UK since his marriage to Cate in February 2007. Has UK taxable income of 125,000 in the tax year 2014/15. Realises chargeable gains each year from disposals of UK assets equal to the capital gains tax annual exempt amount. Sold an investment property in Goland
33、 in February 2015 for 130,000, realising a chargeable gain of 70,000.None of the proceeds from the sale of this property have been remitted to the UK. Required:（分数：20.01）(1).(a) Calculate the annual cost for Cate, after income tax and national insurance contributions, of D-Designs employing the part
34、-time employee. (9 marks)（分数：6.67）_(2).(b) Discuss whether the profit from Cates proposed sale of books via the internet will be liable to either income tax or capital gains tax. (5 marks)（分数：6.67）_(3).(c) Advise Ravi on the options available to him for calculating his UK capital gains tax liability
35、 for the tax year 2014/15. Provide supporting calculations of the tax payable by him in each case. (6 marks)（分数：6.67）_ACCA 考试 P6 高级税务（United+Kingdom）真题 2015 年 6 月答案解析(总分：120.02，做题时间：180 分钟)一、SUPPLEMENTARY INSTRU(总题数：1，分数：0.00)1.1.Your manager has received a letter from Jodie in connection with her p
36、roposed emigration from the UK. Extracts from the letter and from an email from your manager are set out below. Extract from the letter from Jodie Extract from an email from your manager (a) UK tax residence status and liability to UK income tax. (7 marks) (b) Relief available in respect of the trad
37、ing loss. (8 marks) (c) Capital gains tax. (11 marks) (d) Other matters. (5 marks) Professional marks will be awarded for following the managers instructions, the clarity of the explanations and calculations, the effectiveness with which the information is communicated, and the overall presentation.
38、(4 marks) Notes 1. You should assume that the tax rates and allowances for the tax year 2014/15 apply to all tax years. 2. Ignore national insurance contributions throughout this question. (35 marks)（分数：35.00）_正确答案：(Jodie Paragraphs for inclusion in a letter from manager Client Jodie Prepared by Tax
39、 senior Date 5 June 2015 Tax implications of emigration from the UK and related matters (a) UK tax residence status and liability to UK income tax Using the automatic overseas tests it has already been concluded that you will not be automatically regarded as non-UK resident in the tax year 2016/17.
40、It is therefore necessary to consider the automatic UK residence tests. Applying these, you will also not be regarded as UK resident because you will not: be in the UK for 183 days or more; or have a home in the UK but no home overseas; or work in the UK. Accordingly, because your status cannot be d
41、etermined automatically, it will be determined by the number of ties you have with the UK. Because you have been UK resident in one or more (actually all) of the three tax years preceding 2016/17 and you will be in the UK for between 46 and 90 days in the tax year 2016/17, you will be UK resident if
42、 you satisfy three or more UK ties. I set out the ties below: You can see from this that, if you proceed in accordance with your plans, you will only satisfy one of the UK ties, such that you will not be UK resident in the tax year 2016/17. However, if you were to change your plans (for example, the
43、 number of days which you spend in the UK in 2016/17), this may have an effect on your residence status. As a non-UK resident, you will not be subject to UK income tax on your overseas income. (b) Relief available in respect of the trading loss The terminal trade loss for the final 12 months of trad
44、ing is 22,750 (see appendix). This loss can be offset against your taxable trading profits for the final tax year of trading (however, you have no trading profit in the tax year 2015/16) and the three previous tax years, relieving later years before earlier years. The total tax which you will save by relieving the losses in this way will be 7,500 (see appendix). (c) Capital gains tax Becoming non-UK resident in the tax year 2016/17 As a non-UK resident, you will not be subject to UK capi
