(b) (i) Calculate the inheritance tax (IHT) that will be payable if Debbie were to die today (8 June 2005).Assume that no tax planning measures are taken and that there has been no change in the value of anyof the assets since David’s death. (4 marks)
题目
(b) (i) Calculate the inheritance tax (IHT) that will be payable if Debbie were to die today (8 June 2005).
Assume that no tax planning measures are taken and that there has been no change in the value of any
of the assets since David’s death. (4 marks)
相似考题
更多“(b) (i) Calculate the inheritance tax (IHT) that will be payable if Debbie were to die today (8 June 2005).Assume that no tax planning measures are taken and that there has been no change in the value of anyof the assets since David’s death. (4 marks)”相关问题
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第1题：
(c) Assuming that Joanne registers for value added tax (VAT) with effect from 1 April 2006:
(i) Calculate her income tax (IT) and capital gains tax (CGT) payable for the year of assessment 2005/06.
You are not required to calculate any national insurance liabilities in this sub-part. (6 marks)
正确答案：
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第2题：
(ii) State, giving reasons, the tax reliefs in relation to inheritance tax (IHT) and capital gains tax (CGT) which
would be available to Alasdair if he acquires the warehouse and leases it to Gallus & Co, rather than to
an unconnected tenant. (4 marks)
正确答案：
(ii) Apart from the fact that Alasdair can keep an eye on his tenant, the main advantages are twofold:
IHT: If the firm are the tenants, the property will be land and buildings used in a business carried on by a partnership
in which the donor is a partner. Thus, Alasdair will be able to claim business property relief (BPR) at a rate of 50%
so long as he remains a partner in the firm. However, this relief would not be available until Alasdair has owned
the property for at least two years from his firm taking up the tenancy.
CGT: As Alasdair is a partner in the firm using the building, it will also be a qualifying asset for the purposes of rollover
relief on any gains arising from the disposal of the property. Assuming that Alasdair acquires a replacement asset
which will be used in the trade, the gain on sale can be deferred against the tax base cost of the replacement asset.
In the event that rollover relief cannot be used, any gains on disposal will be subject to business asset taper relief. -
第3题：
(c) Assuming that she will survive until July 2009, advise on the lifetime inheritance tax (IHT) planning
measures that could be undertaken by Debbie, quantifying the savings that can be made. (7 marks)
For this question you should assume that the rates and allowances for 2004/05 apply throughout.
正确答案：
(c) Debbie survives until July 2009
Debbie should consider giving away some of her assets to her children, while ensuring that she still has enough to live on.
Such gifts would be categorised as PETs. Although Debbie will not survive seven years (at which point the gifts would fall out
of Debbie’s estate for IHT purposes), taper relief will reduce the amount chargeable to IHT. If gifts were made prior to July
2005, 40% taper relief would be available.
It is important to remember that Debbie’s annual exemptions will reduce the value of any PET when assets are gifted. Debbie
has not used her annual exemption for the last two years, and so she can gift ￡6,000 (2 x ￡3,000) in the current tax year
as well as ￡3,000 per year in future tax years. Debbie could therefore give away ￡18,000, saving tax of ￡7,200 (￡18,000
x 40%). Debbie can also make small exempt gifts of up to ￡250 per donee per year.
Debbie should consider making gifts to Allison’s children instead of Allison (using, for example, an accumulation &
maintenance trust). This would ensure that the gifts were excluded from Allison’s estate.
It does not make sense for Debbie to gift shares in Dee Limited, as these qualify for full business property relief and therefore
are not subject to IHT.
As Andrew is shortly to be married, Debbie could give up to ￡5,000 in consideration of his marriage. This would save ￡2,000
in IHT.
Expenditure out of normal income is also exempt from IHT. This is where the transferor is left with sufficient income to
maintain his/her usual standard of living. Broadly, you need to demonstrate evidence of a prior commitment, or a settled
pattern of expenditure.
If substantial gifts are made, the donees would be advised to consider taking out insurance policies on Debbie’s life to cover
the potential tax liabilities that may arise on PETs in the event of her early death. -
第4题：
(b) Mabel has two objectives when making the gifts to Bruce and Padma:
(1) To pay no tax on any gift in her lifetime; and
(2) To reduce the eventual liability to inheritance tax on her death.
Advise Mabel which item to gift to Bruce and to Padma in order to satisfy her objectives. Give reasons for
your advice.
Your advice should include a computation of the inheritance tax saved as a result of the two gifts, on the
assumption that Mabel dies on 30 June 2011. (10 marks)
正确答案：
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第5题：
(d) Explain how Gloria would be taxed in the UK on the dividends paid by Bubble Inc and the capital gains tax
and inheritance tax implications of a future disposal of the shares. Clearly state, giving reasons, whether or
not the payment made to Eric is allowable for capital gains tax purposes. (9 marks)
You should assume that the rates and allowances for the tax year 2005/06 apply throughout this question.
正确答案：
(d) UK tax implications of shares in Bubble Inc
Income tax
Gloria is UK resident and is therefore subject to income tax on her worldwide income. However, because she is non-UK
domiciled, she will only be taxed on the foreign dividends she brings into the UK.
Dividends brought into the UK will be grossed up for any tax paid in Oceania. The gross amount is taxed at 10% if it falls
into the starting or basic rate band and at 321/2% if it falls into the higher rate band. The tax suffered in Oceania is available
for offset against the UK tax liability. The offset is restricted to a maximum of the UK tax on the dividend income.
Capital gains tax
Individuals are subject to capital gains tax on worldwide assets if they are resident or ordinarily resident in the UK. However,
because Gloria is non-UK domiciled and the shares are situated abroad, the gain is only taxable to the extent that the sales
proceeds are brought into the UK. Any tax suffered in Oceania in respect of the gain is available for offset against the UK
capital gains tax liability arising on the shares.
Any loss arising on the disposal of the shares would not be available for relief in the UK.
In computing a capital gain or allowable loss, a deduction is available for the incidental costs of acquisition. However, to be
allowable, such costs must be incurred wholly and exclusively for the purposes of acquiring the asset. The fee paid to Eric
related to general investment advice and not to the acquisition of the shares and therefore, would not be deductible in
computing the gain.
Taper relief will be at non-business asset rates as Bubble Inc is an investment company.
Inheritance tax
Assets situated abroad owned by non-UK domiciled individuals are excluded property for the purposes of inheritance tax.
However, Gloria will be deemed to be UK domiciled (for the purposes of inheritance tax only) if she has been resident in the
UK for 17 out of the 20 tax years ending with the year in which the disposal occurs.
Gloria has been running a business in the UK since June 1992 and would therefore, appear to have been resident for at least
15 tax years (1992/93 to 2006/07 inclusive).
If Gloria is deemed to be UK domiciled such that the shares in Bubble Inc are not excluded property, business property relief
will not be available because Bubble Inc is an investment company. -
第6题：
(c) Explain the capital gains tax (CGT) and income tax (IT) issues Paul and Sharon should consider in deciding
which form. of trust to set up for Gisella and Gavin. You are not required to consider inheritance tax (IHT) or
stamp duty land tax (SDLT) issues. (10 marks)
You should assume that the tax rates and allowances for the tax year 2005/06 apply throughout this question.
正确答案：
(c) As the trust is created in the settlors’ (Paul and Sharon’s) lifetime its creation will constitute a chargeable disposal for capital
gains tax. Also, as the settlors and trustees are connected persons, the disposal will be deemed to be at market value, resulting
in a chargeable gain of ￡80,000 (160,000 – 80,000). No taper relief will be available as the property is a non-business
asset, and has been held for less than three years, but annual exemptions of ￡17,000 (2 x ￡8,500) will be available.
However, in the case of a discretionary trust, gift hold over relief will be available. This is because the gift will constitute a
chargeable lifetime transfer and because there is an immediate charge to inheritance tax (even though no tax is payable due
to the nil rate band) relief is available if a specific accumulation and maintenance trust is used, as in this case the gift will
qualify as a potentially exempt transfer and so gift relief would only be available in respect of business assets. The use of a
basic discretionary trust will thus facilitate the deferral of an immediate capital gains tax charge of ￡25,200 (63,000 x 40%).
If/when the property is disposed of, however, the trustees will pay capital gains tax on the deferred gain at the trust income
tax rate of 40%, and have an annual exemption of only ￡4,250 (50% of the normal individual rate) available to them. The
40% rate of tax and lower annual exemption rate also apply to chargeable gains arising in a specific accumulation and
maintenance trust, as well as a basic discretionary trust.
A chargeable disposal between connected persons will also arise for the purposes of capital gains tax if/when the property
vests in a beneficiary, i.e. one or more of the beneficiaries becomes absolutely entitled to all or part of the income or capital
of the trust. Gift hold over relief will again be available on all assets in the case of a discretionary trust, but only on business
assets in the case of an accumulation and maintenance trust, except where a beneficiary becomes entitled to both income
and capital at the same time.
The trust will have taxable property income in the form. of net rents from its creation and in future years is also likely to have
other investment income, probably in the form. of interest, to the extent that monies are retained in the trust. Whichever form
of trust is used, the trustees will pay tax at the standard trust rate of 40% on income other than dividend income (32·5%),
except to the extent of (1) the first ￡500 of taxable income, which is taxed at the rate that would otherwise apply to such
income (i.e. 22% for non-savings (rental) income, 20% for savings income (interest) and 10% for dividends) but, only to the
extent that it is not distributed; and (2) the legitimate trust management expenses, which are offsettable for the purposes of
the higher trust tax rates against the income with the lowest rate(s) of normal tax and so bear tax only at that rate. The higher
trust tax rate always applies to income that is distributed, other than to the extent that it has been treated as the settlor’s
income, and taxed at that settlor’s marginal tax rate.
As Paul and Sharon intend to create a trust for their unmarried minor (under 18) children, then even if the trust specifically
excludes them from any benefit under the trust, the trust income will be treated as theirs for income tax purposes to the extent
that it constitutes income paid for on behalf (including maintenance payments) of Gisella and Gavin; except where (1) the
total income arising does not exceed ￡100 gross per annum, and (2) income is held for the benefit of a child under an
accumulation and maintenance settlement, to the extent that it is not paid out. -
第7题：
(b) For this part, assume today’s date is 1 May 2010.
Bill and Ben decided not to sell their company, and instead expanded the business themselves. Ben, however,
is now pursuing other interests, and is no longer involved with the day to day activities of Flower Limited. Bill
believes that the company would be better off without Ben as a voting shareholder, and wishes to buy Ben’s
shares. However, Bill does not have sufficient funds to buy the shares himself, and so is wondering if the
company could acquire the shares instead.
The proposed price for Ben’s shares would be ￡500,000. Both Bill and Ben pay income tax at the higher rate.
Required:
Write a letter to Ben:
(1) stating the income tax (IT) and/or capital gains tax (CGT) implications for Ben if Flower Limited were to
repurchase his 50% holding of ordinary shares, immediately in May 2010; and
(2) advising him of any available planning options that might improve this tax position. Clearly explain any
conditions which must be satisfied and quantify the tax savings which may result.
(13 marks)
Assume that the corporation tax rates for the financial year 2005 and the income tax rates and allowances
for the tax year 2005/06 apply throughout this question.
正确答案：(b) [Ben’s address] [Firm’s address]
Dear Ben [Date]
A company purchase of own shares can be subject to capital gains treatment if certain conditions are satisfied. However, one
of these conditions is that the shares in question must have been held for a minimum period of five years. As at 1 May 2010,
your shares in Flower Limited have only been held for four years and ten months. As a result, the capital gains treatment will
not apply.
In the absence of capital gains treatment, the position on a company repurchase of its own shares is that the payment will
be treated as an income distribution (i.e. a dividend) in the hands of the recipient. The distribution element is calculated as
the proceeds received for the shares less the price paid for them. On the basis that the purchase price is ￡500,000, then the
element of distribution will be ￡499,500 (500,000 – 500). This would be taxed as follows:
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第8题：
1 Alvaro Pelorus is 47 years old and married to Maria. The couple have two children, Vito and Sophie, aged 22 and
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)
正确答案：
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第9题：
(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)
正确答案：
(c) (i) Variation of Ray’s will
The variation by Alvaro of Ray’s will, such that assets are left to Vito and Sophie, will not be regarded as a gift by Alvaro.
Instead, provided the deed states that it is intended to be effective for IHT purposes, it will be as if Ray had left the assets
to the children in his will.
This strategy, known as skipping a generation, will have no effect on the IHT due on Ray’s death but will reduce the
assets owned by Alvaro and thus his potential UK IHT liability. A deed of variation is more tax efficient than Alvaro
making gifts to the children as such gifts would be PETs and IHT may be due if Alvaro were to die within seven years.
The deed of variation must be entered into by 31 January 2009, i.e. within two years of the date of Ray’s death. -
第10题：
(c) The inheritance tax payable by Adam in respect of the gift from his aunt. (4 marks)
Additional marks will be awarded for the appropriateness of the format and presentation of the memorandum and
the effectiveness with which the information is communicated. (2 marks)
Note: you should assume that the tax rates and allowances for the tax year 2006/07 will continue to apply for the
foreseeable future.
正确答案：
(c) Inheritance tax payable by Adam
The gift by AS’s aunt was a potentially exempt transfer. No tax will be due if she lives until 1 June 2014 (seven years after
the date of the gift).
The maximum possible liability, on the assumption that there are no annual exemptions or nil band available, is ￡35,216
(￡88,040 x 40%). This will only arise if AS’s aunt dies before 1 June 2010.
The maximum liability will be reduced by taper relief of 20% for every full year after 31 May 2010 for which AS’s aunt lives.
The liability will also be reduced if the chargeable transfers made by the aunt in the seven years prior to 1 June 2007 are
less than ￡285,000 or if the annual exemption for 2006/07 and/or 2007/08 is/are available. -
第11题：
(c) (i) Calculate Benny’s capital gains tax liability for 2006/07. (6 marks)
正确答案：
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第12题：
问答题Inheritance tax is a tax which many countries levy on the total taxable value of the estate of a deceased person. Inheritance tax is paid by the inheritor of the estate or by the person in charge of its assets. In most cases, if the estate is left to a charitable organization or a surviving spouse, no inheritance tax is due. In China, inheritance tax does not exist. Should inheritance tax be introduced to China? The controversy that has raged over levying inheritance tax in China currently shows little sign of abating. The following are opinions from both sides. Read the excerpt carefully and write your response in about 300 words, in which you should: 1. summarize briefly the opinions from both sides, and then 2. give your comment. Marks will be awarded for content relevance, content sufficiency, organization and language quality. Failure to follow the above instructions may result in a loss of marks. Opponents of inheritance tax typically refer to it as “death tax.” They argue first that concern over burdening their children with this tax may lead elderly to make unwise investment decisions late in life, and that it may also discourage entrepreneurship earlier in life. Opponents also claim that morally it should be only the choice of the person who earned the money what should be done with it, not the government. They see taxing wealth at death as a kind of forced income redistribution that goes against the market economy. Proponents of inheritance tax say that it helps prevent consolidation of wealth in the hands of a few powerful families and is a basic building block of the nation’s system of taxation. They also feel that inheriting large sums without tax undermines people’s motives to work hard in the future and, thus, undercuts the principles of the market economy, encouraging people to become idle and unproductive, which hurts the country overall.正确答案：
【参考范文】
Should Inheritance Tax be Introduced to China? An inheritance tax is a tax paid by a person who inherits money or property or a levy on the estate of a person who has died. Many countries have inheritance tax, while China does not. Whether China should levy inheritance tax has become a hot topic of discussion. Supporters hold that it helps prevent the wealth from being always in the hands of a few powerful families. Inheriting large sums without tax weakens people’s enthusiasm for work, encouraging people to become lazy and unproductive, which is not conducive to the whole country. However, opponents argue that this tax may result in unwise investment decisions late in life, and discourage entrepreneurship earlier in life. It is a kind of forced income redistribution, ignoring the right of people earned the money.
From my points of view, inheritance tax should not be introduced to China. Firstly, it is a violation of human rights. In any country that has recognized the private property rights, a person’s private property can be handled without violating others all a person likes. The inheritance tax violates the rights of the people to dispose of their property. Secondly, inheritance tax will encourage abnormal consumption, conspicuous consumption of rich people, further intensifying contradictions and conflicts among social members. It may stimulate the rich to spend their money excessively before death and lead to hostility to the rich. Thirdly, inheritance tax will reduce the enthusiasm of entrepreneurs, exacerbate capital flight, economic migration and impede investment and capital inflows, inhibiting economic development. It may drive wealthy people to move assets out of the country or emigrate in order to avoid the tax, resulting in capital loss and brain drain.
To summarize, inheritance tax might not be an effective enough tool to narrow income disparity. Therefore, other measures are needed if the government wants to ensure a more equitable distribution of wealth in society.解析：
【审题构思】
本题要求考生围绕是否应该征收遗产税这一话题展开讨论。文章可以支持也可以反对，只要言之有理即可。考生首先要总结材料中的观点，然后明确陈述自己的观点。接下来论证自己的观点，注意要分点列举，这样才能做到内容充实，条理清晰。最后总结全文，重申观点；也可进一步补充观点，深化主题。 -
第13题：
(ii) Calculate her income tax (IT) and national insurance (NIC) payable for the year of assessment 2006/07.
(4 marks)
正确答案：
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第14题：
(ii) State when the inheritance tax (IHT) calculated in (i) would be payable and by whom. (2 marks)
正确答案：
(ii) Inheritance tax administration
The tax on Debbie’s estate (personalty and realty) would be paid by the personal representatives, usually an executor.
Inheritance tax is due six months from the end of the month in which death occurred (31 December 2005) or the date
on which probate is obtained (if earlier). However, an instalment option is available for certain assets, which includes
land and buildings i.e. the residence whereby the tax can be paid in 10 equal annual instalments. -
第15题：
3 Assume that today’s date is 10 May 2005.
You have recently been approached by Fred Flop. Fred is the managing director and 100% shareholder of Flop
Limited, a UK trading company with one wholly owned subsidiary. Both companies have a 31 March year-end.
Fred informs you that he is experiencing problems in dealing with aspects of his company tax returns. The company
accountant has been unable to keep up to date with matters, and Fred also believes that mistakes have been made
in the past. Fred needs assistance and tells you the following:
Year ended 31 March 2003
The corporation tax return for this period was not submitted until 2 November 2004, and corporation tax of ￡123,500
was paid at the same time. Profits chargeable to corporation tax were stated as ￡704,300.
A formal notice (CT203) requiring the company to file a self-assessment corporation tax return (dated 1 February
2004) had been received by the company on 4 February 2004.
A detailed examination of the accounts and tax computation has revealed the following.
– Computer equipment totalling ￡50,000 had been expensed in the accounts. No adjustment has been made in
the tax computation.
– A provision of ￡10,000 was made for repairs, but there is no evidence of supporting information.
– Legal and professional fees totalling ￡46,500 were allowed in full without any explanation. Fred has
subsequently produced the following analysis:
Analysis of legal & professional fees
￡
Legal fees on a failed attempt to secure a trading loan 15,000
Debt collection agency fees 12,800
Obtaining planning consent for building extension 15,700
Accountant’s fees for preparing accounts 14,000
Legal fees relating to a trade dispute 19,000
– No enquiry has yet been raised by the Inland Revenue.
– Flop Ltd was a large company in terms of the Companies Act definition for the year in question.
– Flop Ltd had taxable profits of ￡595,000 in the previous year.
Year ended 31 March 2004
The corporation tax return has not yet been submitted for this year. The accounts are late and nearing completion,
with only one change still to be made. A notice requiring the company to file a self-assessment corporation tax return
(CT203) dated 27 July 2004 was received on 1 August 2004. No corporation tax has yet been paid.
1 – The computation currently shows profits chargeable to corporation tax of ￡815,000 before accounting
adjustments, and any adjustments for prior years.
– A company owing Flop Ltd ￡50,000 (excluding VAT) has gone into liquidation, and it is unlikely that any of this
money will be paid. The money has been outstanding since 3 September 2003, and the bad debt will need to
be included in the accounts.
1 Fred also believes there are problems in relation to the company’s VAT administration. The VAT return for the quarter
ended 31 March 2005 was submitted on 5 May 2005, and VAT of ￡24,000 was paid at the same time. The previous
return to 31 December 2004 was also submitted late. In addition, no account has been made for the VAT on the bad
debt. The VAT return for 30 June 2005 may also be late. Fred estimates the VAT liability for that quarter to be ￡8,250.
Required:
(a) (i) Calculate the revised corporation tax (CT) payable for the accounting periods ending 31 March 2003
and 2004 respectively. Your answer should include an explanation of the adjustments made as a result
of the information which has now come to light. (7 marks)
(ii) State, giving reasons, the due payment date of the corporation tax (CT) and the filing date of the
corporation tax return for each period, and identify any interest and penalties which may have arisen to
date. (8 marks)
正确答案：(a) Calculation of corporation tax
Year ended 31 March 2003
Corporation tax payable
There are three adjusting items:.
(i) The computers are capital items, as they have an enduring benefit. These need to be added back in the Schedule D
Case I calculation, and capital allowances claimed instead. The company is not small or medium by Companies Act
definitions and therefore no first year allowances are available. Allowances of ￡12,500 (50,000 x 25%) can be claimed,
leaving a TWDV of ￡37,500.
(ii) The provision appears to be general in nature. In addition there is insufficient information to justify the provision and it
should be disallowed until such times as it is released or utilised.
(iii) Costs relating to trading loan relationships are allowable, as are costs relating to the trade (debt collection, trade disputes
and accounting work). Costs relating to capital items (￡5,700) are not allowable so will have to be added back.
Total profit chargeable to corporation tax is therefore ￡704,300 + 50,000 – 12,500 + 10,000 + 5,700 = 757,500. There are two associates, and therefore the 30% tax rate starts at ￡1,500,000/2 = ￡750,000. Corporation tax payable is 30% x￡757,500 = ￡227,250.
Payment date
Although the rate of tax is 30% and the company ‘large’, quarterly payments will not apply, as the company was not large in the previous year. The due date for payment of tax is therefore nine months and one day after the end of the tax accounting period (31 March 2003) i.e. 1 January 2004.
Filing date
This is the later of:
– 12 months after the end of the period of account: 31 March 2004
– 3 months after the date of the notice requiring the return 1 May 2004
i.e. 1 May 2004.
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第16题：
(c) Without changing the advice you have given in (b), or varying the terms of Luke’s will, explain how Mabel
could further reduce her eventual inheritance tax liability and quantify the tax saving that could be made.
(3 marks)
The increase in the retail prices index from April 1984 to April 1998 is 84%.
You should assume that the rates and allowances for the tax year 2005/06 will continue to apply for the
foreseeable future.
正确答案：
(c) Further advice
Mabel should consider delaying one of the gifts until after 1 May 2007 such that it is made more than seven years after the
gift to the discretionary trust. Both PETs would then be covered by the nil rate band resulting in a saving of inheritance tax
of ￡6,720 (from (b)).
Mabel should ensure that she uses her inheritance tax annual exemption of ￡3,000 every year by, say, making gifts of ￡1,500
each year to both Bruce and Padma. The effect of this will be to save inheritance tax of ￡1,200 (￡3,000 x 40%) every year. -
第17题：
(b) Calculate the inheritance tax (IHT) liability arising as a result of Christopher’s death. (11 marks)
正确答案：
-
第18题：
(iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of inserting Bold plc as
a holding company and identify any planning actions that can be taken to defer or minimise these tax
costs. (4 marks)
You should assume that the corporation tax rates for the financial year 2005 and the income tax rates
and allowances for the tax year 2005/06 apply throughout this question.
正确答案：
(iii) Bold plc will be making a taxable supply of services, likely to exceed the VAT threshold. It should therefore consider
registering for VAT – either immediately on a voluntary basis, or when its cumulative taxable supplies in the previous
twelve months exceed ￡60,000.
As an alternative, the new group can apply for a group VAT registration. This will simplify its VAT administration as intragroup
transactions are broadly disregarded for VAT purposes, and only one VAT return is required for the group as a
whole.
Stamp duty normally applies at 0·5% on the consideration payable in respect of transactions in shares. However, an
exemption is available in the case of a takeover, reconstruction or amalgamation where there is no real change in
ownership, i.e. the new shareholdings mirror the old shareholdings, and the transaction is for commercial purposes. The
insertion of a new holding company over an existing company, as proposed here, would qualify for this exemption.
There is no VAT on transactions in shares. -
第19题：
(ii) Calculate the corporation tax (CT) payable by Tay Limited for the year ended 31 March 2006, taking
advantage of all available reliefs. (3 marks)
正确答案：
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第20题：
(b) Calculate Alvaro Pelorus’s capital gains tax liability for the tax year 2006/07 on the assumption that all
available reliefs are claimed. (8 marks)
正确答案：
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第21题：
(b) (i) Calculate Amanda’s income tax payable for the tax year 2006/07; (11 marks)
正确答案：
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第22题：
(c) On the assumption that the administrators of Noland’s estate will sell quoted shares in order to fund the
inheritance tax due as a result of his death, calculate the value of the quoted shares that will be available to
transfer to Avril. You should include brief notes of your treatment of the house and the shares in Kurb Ltd.
(9 marks)
Note: you should assume that the tax rates and allowances for the tax year 2006/07 apply throughout this
question.
正确答案：(c) Value of quoted shares that can be transferred to Avril
The value of shares to be transferred to Avril will be equal to ￡370,000 less the inheritance tax due by the estate.
IHT is payable on transfers in the seven years prior to Noland’s death and on the death estate.
The only chargeable gift in the seven years prior to Noland’s death is the transfer to the discretionary trust. No tax is due in
respect of this gift as it is covered by the nil rate band.
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第23题：
James died on 22 January 2015. He had made the following gifts during his lifetime:
(1) On 9 October 2007, a cash gift of ￡35,000 to a trust. No lifetime inheritance tax was payable in respect of this gift.
(2) On 14 May 2013, a cash gift of ￡420,000 to his daughter.
(3) On 2 August 2013, a gift of a property valued at ￡260,000 to a trust. No lifetime inheritance tax was payable in respect of this gift because it was covered by the nil rate band. By the time of James’ death on 22 January 2015, the property had increased in value to ￡310,000.
On 22 January 2015, James’ estate was valued at ￡870,000. Under the terms of his will, James left his entire estate to his children.
The nil rate band of James’ wife was fully utilised when she died ten years ago.
The nil rate band for the tax year 2007–08 is ￡300,000, and for the tax year 2013–14 it is ￡325,000.
Required:
(a) Calculate the inheritance tax which will be payable as a result of James’ death, and state who will be responsible for paying the tax. (6 marks)
(b) Explain why it might have been beneficial for inheritance tax purposes if James had left a portion of his estate to his grandchildren rather than to his children. (2 marks)
(c) Explain why it might be advantageous for inheritance tax purposes for a person to make lifetime gifts even when such gifts are made within seven years of death.
Notes:
1. Your answer should include a calculation of James’ inheritance tax saving from making the gift of property to the trust on 2 August 2013 rather than retaining the property until his death.
2. You are not expected to consider lifetime exemptions in this part of the question. (2 marks)
正确答案：(a) James – Inheritance tax arising on death
Lifetime transfers within seven years of death
The personal representatives of James’ estate will be responsible for paying the inheritance tax of ￡348,000.
Working – Available nil rate band
(b) Skipping a generation avoids a further charge to inheritance tax when the children die. Gifts will then only be taxed once before being inherited by the grandchildren, rather than twice.
(c) (1) Even if the donor does not survive for seven years, taper relief will reduce the amount of IHT payable after three years.
(2) The value of potentially exempt transfers and chargeable lifetime transfers are fixed at the time they are made.
(3) James therefore saved inheritance tax of ￡20,000 ((310,000 – 260,000) at 40%) by making the lifetime gift of property.