在EPC模式中，采购主要是指（）

(ii) Advise Mr Fencer of the income tax implications of the proposed financing arrangements. (2 marks)

(ii) Advise Andrew of the tax implications arising from the disposal of the 7% Government Stock, clearly

identifying the tax year in which any liability will arise and how it will be paid. (3 marks)

(b) (i) Advise Benny of the income tax implications of the grant and exercise of the share options in Summer

Glow plc on the assumption that the share price on 1 September 2007 and on the day he exercises the

options is ￡3·35 per share. Explain why the share option scheme is not free from risk by reference to

the rules of the scheme and the circumstances surrounding the company. (4 marks)

(ii) Advise Clifford of the capital gains tax implications of the alternative of selling the Oxford house and

garden by means of two separate disposals as proposed. Calculations are not required for this part of

the question. (3 marks)

(b) Explain the corporation tax and value added tax (VAT) implications of the following aspects of the proposed

restructuring of the Rapier Ltd group.

(i) The immediate tax implications of the restructuring. (6 marks)

(c) State the tax consequences for both Glaikit Limited and Alasdair if he borrows money from the company, as

proposed, on 1 January 2006. (3 marks)

(c) (i) Explain the capital gains tax (CGT) implications of a takeover where the consideration is in the form. of

shares (a ‘paper for paper’ transaction) stating any conditions that need to be satisfied. (4 marks)

(b) (i) Advise Andrew of the income tax (IT) and capital gains tax (CGT) reliefs available on his investment in

the ordinary share capital of Scalar Limited, together with any conditions which need to be satisfied.

Your answer should clearly identify any steps that should be taken by Andrew and the other investors

to obtain the maximum relief. (13 marks)

(b) (i) State the condition that would need to be satisfied for the exercise of Paul’s share options in Memphis

plc to be exempt from income tax and the tax implications if this condition is not satisfied.

(2 marks)

(c) (i) Explain the inheritance tax (IHT) implications and benefits of Alvaro Pelorus varying the terms of his

father’s will such that part of Ray Pelorus’s estate is left to Vito and Sophie. State the date by which a

deed of variation would need to be made in order for it to be valid; (3 marks)