(b) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of t

(b) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of the new premises in the

year ending 31 March 2009 and explain, using illustrative calculations, how any additional recoverable input

tax will be calculated in future years. (5 marks)

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  • 提问人:00****06
  • 发布时间:2012-12-03
3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans toexpand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell hershares back to the company. Once the purchase of her shares has taken place, the company intends to establish anumber of branches overseas and acquire a shareholding in a number of companies that are resident and trade inoverseas countries.The following information has been obtained from client files and meetings with the parties involved.Acrux Ltd:– An unquoted UK resident company.– Share capital consists of 50,000 ordinary shares issued at £1·90 per share in July 2000.– None of the other shareholders has any connection with Spica.The purchase of own shares:– The company will purchase all of Spica’s shares for £8 per share.– The transaction will take place by the end of 2008.Spica:– Purchased 8,000 shares in Acrux Ltd for £2 per share on 30 September 2003.– Has no income in the tax year 2008/09.– Has chargeable capital gains in the tax year 2008/09 of £3,800.– Has houses in the UK and the country of Solaris and divides her time between them.Investment in non-UK resident companies:– Acrux Ltd will acquire between 15% and 20% of each of the non-UK resident companies.– The companies will not be controlled foreign companies as the rates of tax in the overseas countries will bebetween 23% and 42%.– There may or may not be a double tax treaty between the UK and the overseas countries in which the companiesare resident. Where there is a treaty, it will be based on the OECD model treaty.– None of the countries concerned levy withholding tax on dividends paid to UK companies.– The directors of Acrux Ltd are concerned that the rate of tax suffered on the profits of the overseas companieswill be very high as they will be taxed in both the overseas country and in the UK.Required:(a) (i) Prepare detailed calculations to determine the most beneficial tax treatment of the payment Spica willreceive for her shares; (7 marks)
(ii) Identify the points that must be confirmed and any action necessary in order for capital treatment toapply to the transaction. (4 marks)
(b) Provide the directors of Acrux Ltd with a detailed explanation of the maximum rate of tax that will be sufferedon both the distributed and non-distributed profits of the non-UK resident investee companies where:(1) there is a double tax treaty between the UK and the country in which the individual companies areresident; and(2) there is no such double tax treaty.Note: you are not required to explain the position of the overseas resident branches. (6 marks)
Galileo:– Resident, ordinarily resident and domiciled in the country of Astronomeria where he has lived since birth.– Lives in rented accommodation in Astronomeria.– Intends to sell two paintings in order to provide funds to go towards the cost of relocating to the UK andpurchasing a house here.– Has a full time employment contract with Messier Ltd commencing on 1 September 2008.– Intends to stay in the UK for at least five years.The two paintings:– Are situated in Astronomeria and are worth approximately £20,000 each.– Have been owned by Galileo since 1 May 1994; their cost is negligible and can be ignored.Employment contract with Messier Ltd:– Galileo will be paid an annual salary of £52,000.– Messier Ltd will assist Galileo with the cost of relocating to the UK.Required:(a) (i) Calculate the inheritance tax payable (if any) by Galileo in respect of (1) the gift of shares in June 2004and (2) the inheritance of shares in May 2008; (7 marks)



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