（ii) On 1 July 2006 Petrie introduced a 10-year warranty on all sales of its entire range

(ii) Assuming the new structure is implemented with effect from 1 August 2006, calculate the level of

management charge that should be made by Bold plc to Linden Limited for the year ended 31 July

2007, so as to minimise the group’s overall corporation tax (CT) liability for that year. (2 marks)

19 years respectively. Alvaro and Maria have lived in the country of Koruba since 1982. On 1 July 2005 the family

moved to the UK to be near Alvaro’s father, Ray, who was very ill. Alvaro and Maria are UK resident, but not ordinarily

resident in the tax years 2005/06 and 2006/07. They are both domiciled in the country of Koruba.

On 1 February 2007 Ray Pelorus died. He was UK domiciled, having lived in the UK for the whole of his life. For the

purposes of inheritance tax, his death estate consisted of UK assets, valued at ￡870,000 after deduction of all

available reliefs, and a house in the country of Pacifica valued at ￡94,000. The executors of Ray’s estate have paid

Pacifican inheritance tax of ￡1,800 and legal fees of ￡7,700 in respect of the sale of the Pacifican house. Ray left

the whole of his estate to Alvaro.

Ray had made two gifts during his lifetime:

(i) 1 May 2003: He gave Alvaro 95 acres of farm land situated in the UK. The market value of the land was

￡245,000, although its agricultural value was only ￡120,000. Ray had acquired the land on

1 January 1996 and granted an agricultural tenancy on that date. Alvaro continues to own the

land as at today’s date and it is still subject to the agricultural tenancy.

(ii) 1 August 2005: He gave Alvaro 6,000 shares valued at ￡183,000 in Pinger Ltd, a UK resident trading

company. Gift relief was claimed in respect of this gift. Ray had acquired 14,000 shares in

Pinger Ltd on 1 April 1997 for ￡54,600.

You may assume that Alvaro is a higher rate taxpayer for the tax years 2005/06 and 2006/07. In 2006/07 he made

the following disposals of assets:

(i) On 1 July 2006 he sold the 6,000 shares in Pinger Ltd for ￡228,000.

(ii) On 1 September 2006 he sold 2,350 shares in Lapis Inc, a company resident in Koruba, for ￡8,270. Alvaro

had purchased 5,500 shares in the company on 1 September 2002 for ￡25,950.

(iii) On 1 December 2006 he transferred shares with a market value of ￡74,000 in Quad plc, a UK quoted company,

to a UK resident discretionary trust for the benefit of Vito and Sophie. Alvaro had purchased these shares on

1 January 2006 for ￡59,500.

Alvaro has not made any other transfers of value for the purposes of UK inheritance tax. He owns the family house

in the UK as well as shares in UK and Koruban companies and commercial rental property in the country of Koruba.

Maria has not made any transfers of value for the purposes of UK inheritance tax. Her only significant asset is the

family home in the country of Koruba.

Alvaro and his family expect to return to their home in the country of Koruba in October 2007 once Ray’s affairs have

been settled. There is no double taxation agreement between the UK and Koruba.

Required:

(a) Calculate the inheritance tax (IHT) payable as a result of the death of Ray Pelorus. Explain the availability

or otherwise of agricultural property relief and business property relief on the two lifetime gifts made by Ray.

(8 marks)

(b) Misson has purchased goods from a foreign supplier for 8 million euros on 31 July 2006. At 31 October 2006,

the trade payable was still outstanding and the goods were still held by Misson. Similarly Misson has sold goods

to a foreign customer for 4 million euros on 31 July 2006 and it received payment for the goods in euros on

31 October 2006. Additionally Misson had purchased an investment property on 1 November 2005 for

28 million euros. At 31 October 2006, the investment property had a fair value of 24 million euros. The company

uses the fair value model in accounting for investment properties.

Misson would like advice on how to treat these transactions in the financial statements for the year ended 31

October 2006. (7 marks)

Required:

Discuss the accounting treatment of the above transactions in accordance with the advice required by the

directors.

(Candidates should show detailed workings as well as a discussion of the accounting treatment used.)

(iv) Tyre recently undertook a sales campaign whereby customers can obtain free car accessories, by presenting a

coupon, which has been included in an advertisement in a national newspaper, on the purchase of a vehicle.

The offer is valid for a limited time period from 1 January 2006 until 31 July 2006. The management are unsure

as to how to treat this offer in the financial statements for the year ended 31 May 2006.

(5 marks)

Required:

Advise the directors of Tyre on how to treat the above items in the financial statements for the year ended

31 May 2006.

(The mark allocation is shown against each of the above items)

rate taxpayer who has realised taxable capital gains in 2007/08 in excess of his capital gains tax annual exemption.

Clifford moved into Amanda’s house in London on the day they were married. Clifford’s own house in Oxford, where

he had lived since acquiring it for ￡129,400 on 1 August 1996, has been empty since that date although he and

Amanda have used it when visiting friends. Clifford has been offered ￡284,950 for the Oxford house and has decided

that it is time to sell it. The house has a large garden such that Clifford is also considering an offer for the house and

a part only of the garden. He would then sell the remainder of the garden at a later date as a building plot. His total

sales proceeds will be higher if he sells the property in this way.

Amanda received the following income from quoted investments in 2006/07:

￡

Dividends in respect of quoted trading company shares 1,395

Dividends paid by a Real Estate Investment Trust out of tax exempt property income 485

On 1 May 2006, Amanda was granted a 22 year lease of a commercial investment property. She paid the landlord

a premium of ￡6,900 and also pays rent of ￡2,100 per month. On 1 June 2006 Amanda granted a nine year

sub-lease of the property. She received a premium of ￡14,700 and receives rent of ￡2,100 per month.

On 1 September 2006 Amanda gave quoted shares with a value of ￡2,200 to a registered charity. She paid broker’s

fees of ￡115 in respect of the gift.

Amanda began working for Shearer plc, a quoted company, on 1 June 2006 having had a two year break from her

career. She earns an annual salary of ￡38,600 and was paid a bonus of ￡5,750 in August 2006 for agreeing to

come and work for the company. On 1 August 2006 Amanda was provided with a fully expensed company car,

including the provision of private petrol, which had a list price when new of ￡23,400 and a CO2 emissions rate of

187 grams per kilometre. Amanda is required to pay Shearer plc ￡22 per month in respect of the private use of the

car. In June and July 2006 Amanda used her own car whilst on company business. She drove 720 business miles

during this two month period and was paid 34 pence per mile. Amanda had PAYE of ￡6,785 deducted from her gross

salary in the tax year 2006/07.

After working for Shearer plc for a full year, Amanda becomes entitled to the following additional benefits:

– The opportunity to purchase a large number of shares in Shearer plc on 1 July 2007 for ￡3·30 per share. It is

anticipated that the share price on that day will be at least ￡7·50 per share. The company will make an interestfree

loan to Amanda equal to the cost of the shares to be repaid in two years.

– Exclusive free use of the company sailing boat for one week in August 2007. The sailing boat was purchased by

Shearer plc in January 2005 for use by its senior employees and costs the company ￡1,400 a week in respect

of its crew and other running expenses.

Required:

(a) (i) Calculate Clifford’s capital gains tax liability for the tax year 2007/08 on the assumption that the Oxford

house together with its entire garden is sold on 31 July 2007 for ￡284,950. Comment on the relevance

to your calculations of the size of the garden; (5 marks)

(ii) Illustrate the benefit of revising the corporate structure by calculating the corporation tax (CT) payable

for the year ended 31 March 2006, on the assumptions that:

(1) no action is taken; and

(2) an amended structure as recommended in (i) above is implemented from 1 June 2005. (3 marks)

Date: 3rd July, 2006

To:All staff

From: Terry Theacher

Subject: Lecture on New Technology

Content:

① a lecture on the latest technology and how we can expect it to affect our work given by Dr. Rhodes

② attendance will be counted toward staff development points required for the end of year uation

③ to sign up before Wednesday if you plan to come.

A、2012

B、2013

C、2014

D、2015

equally. On 28 February 2007 the partners sold the business to Razor Ltd, in exchange for shares in Razor Ltd, with

each former partner owning one third of the new company.

The recent, tax adjusted, trading profits of the Stiletto Partnership have been as follows:

￡

Year ended 30 June 2006 92,124

1 July 2006 to 28 February 2007 81,795

Clint, who was 65 on 5 October 2006, retired when the business was sold to Razor Ltd. He is now suggesting that

if the sale of the partnership, and his retirement, had been delayed until 30 April 2007, his total tax liability would

have been reduced. Clint’s only other income is gross pension income of ￡6,100 per year, which he began receiving

in the tax year 2005/06. Clint did not receive any salary or dividends from Razor Ltd. It is estimated that the

partnership’s tax adjusted trading profits for the period from 1 March 2007 to 30 April 2007 would have been

￡20,760. Clint has overlap profits of ￡14,250 brought forward from when the partnership began trading.

Razor Ltd manufactures industrial cutting tools. On 1 July 2007, Razor Ltd will subscribe for the whole of the ordinary

share capital of Cutlass Inc, a company newly incorporated in the country of Sharpenia. It is intended that Cutlass

Inc will purchase partly finished tools from Razor Ltd and customise them in Sharpenia. It is anticipated that Cutlass

Inc’s annual profits chargeable to corporation tax will be approximately ￡120,000.

Ben and Amy will be the directors of Cutlass Inc, although Ben will not be involved in the company’s business on a

day-to-day basis. Amy intends to spend one or two weeks each month in the country of Sharpenia looking after the

company’s affairs. The remainder of her time will be spent in the UK. Amy has employment contracts with both Razor

Ltd and Cutlass Inc and her duties for Cutlass Inc will be carried out wholly in Sharpenia. Cutlass Inc will pay for

Amy’s flights to and from Sharpenia and for her husband and baby to visit her there twice a year. Amy is currently

UK resident and ordinarily resident.

The system of income tax and corporation tax in the country of Sharpenia is broadly similar to that in the UK although

the rate of corporation tax is 38% regardless of the level of profits. There is a double tax treaty between the UK and

Sharpenia based on the OECD model treaty. The clause in the treaty dealing with company residency states that a

company resident in both countries under domestic law will be regarded under the treaty as being resident only in the

country where it is effectively managed and controlled. Sharpenia is not a member of the European Union.

Required:

(a) (i) Calculate Clint’s taxable trading profits for the tax years 2006/07 and 2007/08 for both of the

alternative retirement dates (28 February 2007 and 30 April 2007). (3 marks)

(c) Lamont owns a residential apartment above its head office. Until 31 December 2006 it was let for $3,000 a

month. Since 1 January 2007 it has been occupied rent-free by the senior sales executive. (6 marks)

Required:

For each of the above issues:

(i) comment on the matters that you should consider; and

(ii) state the audit evidence that you should expect to find,

in undertaking your review of the audit working papers and financial statements of Lamont Co for the year ended

31 March 2007.

NOTE: The mark allocation is shown against each of the three issues.