2 Assume that today’s date is 1 July 2005.Jan is aged 45 and single. He is of Danish domicile but has been working in the United Kingdom since 1 May 2004and intends to remain in the UK for the medium to long term. Although Jan worked briefly in the UK in

题目

2 Assume that today’s date is 1 July 2005.

Jan is aged 45 and single. He is of Danish domicile but has been working in the United Kingdom since 1 May 2004

and intends to remain in the UK for the medium to long term. Although Jan worked briefly in the UK in 1986, he

has forgotten how UK taxation works and needs some assistance before preparing his UK income tax return.

Jan’s salary from 1 May 2004 was £74,760 per annum. Jan also has a company car – a Jaguar XJ8 with a list price

of £42,550 including extras, and CO2 emissions of 242g/km. The car was available to him from 1 July 2004. Free

petrol is provided by the company. Jan has other taxable benefits amounting to £3,965.

Jan’s other 2004/05 income comprises:

Dividend income from UK companies (cash received) 3,240

Interest received on an ISA account 230

Interest received on a UK bank account 740

Interest remitted from an offshore account (net of 15% withholding tax) 5,100

Income remitted from a villa in Portugal (net of 45% withholding tax) 4,598

The total interest arising on the offshore account was £9,000 (gross). In addition, Jan has not remitted other

Portuguese rental income arising in the year, totalling a further £1,500 (gross).

Jan informs you that his employer is thinking of providing him with rented accommodation while he looks for a house

to buy. The accommodation would be a two bedroom flat, valued at £155,000 with an annual value of £6,000. It

would be made available from 6 August 2005. The company will pay the rent of £600 per month for the first six

months. All other bills will be paid by Jan.

Jan also informs you that he has 25,000 ordinary shares in Gilet Ltd (‘Gilet’), an unquoted UK trading company. He

has held these shares since August 1986 when he bought 2,500 shares at £4.07 per share. In January 1994, a

bonus issue gave each shareholder nine shares for each ordinary share held. In the last week all Gilet’s shareholders

have received an offer from Jumper plc (‘Jumper’) who wishes to acquire the shares. Jumper has offered the following:

– 3 shares in Jumper (currently trading at £3.55 per share) for every 5 shares in Gilet, and

– 25p cash per share

Required:

(a) Calculate Jan’s 2004/05 income tax (IT) payable. (11 marks)


相似考题

1.2 Graeme, aged 57, is married to Catherine, aged 58. They work as medical consultants, and both are higher ratetaxpayers. Barry, their son, is aged 32. Graeme, Catherine and Barry are all UK resident, ordinarily resident anddomiciled. Graeme has come to you for some tax advice.Graeme has invested in shares for some time, in particular shares in Thistle Dubh Limited. He informs you of thefollowing transactions in Thistle Dubh Limited shares:(i) In December 1986, on the death of his grandmother, he inherited 10,000 £1 ordinary shares in Thistle DubhLimited, an unquoted UK trading company providing food supplies for sporting events. The probate value of theshares was 360p per share.(ii) In March 1992, he took up a rights issue, buying one share for every two held. The price paid for the rightsshares was £10 per share.(iii) In October 1999, the company underwent a reorganisation, and the ordinary shares were split into two newclasses of ordinary share – ‘T’ shares and ‘D’ shares, each with differing rights. Graeme received two ‘T’ and three‘D’ shares for each original Thistle Dubh Limited share held. The market values for the ‘T’ shares and the ‘D’shares on the date of reorganisation were 135p and 405p per share respectively.(iv) On 1 May 2005, Graeme sold 12,000 ‘T’ shares. The market values for the ‘T’ shares and the ‘D’ shares on thatday were 300p and 600p per share respectively.(v) In October 2005, Graeme sold all of his ‘D’ shares for £85,000.(vi) The current market value of ‘T’ shares is 384p per share. The shares remain unquoted.Graeme and Catherine have owned a holiday cottage in a remote part of the UK for many years. In recent years, theyhave used the property infrequently, as they have taken their holidays abroad and the cottage has been let out asfurnished holiday accommodation.Graeme and Catherine are now considering selling the UK country cottage and purchasing a holiday villa abroad.Initially they plan to let this villa out on a furnished basis, but following their anticipated retirement, would expect tooccupy the property for a significant part of the year themselves, possibly moving to live in the villa permanently.Required:(a) Calculate the total chargeable gains arising on Graeme’s disposals of ‘T’ and ‘D’ ordinary shares in May andOctober 2005 respectively. (7 marks)

4.4 Assume today’s date is 5 February 2006.Joanne is 37, she was born and until 2005 had lived all her life in Germany. She recently married Fraser, aged 38,who is a UK resident, but who worked briefly in Germany. They have no children.The couple moved to the UK to live permanently on 9 October 2005. Joanne was employed by an American companyin Germany, and she continued to work for them in the UK until the end of November 2005. Her earnings from theAmerican company were £5,000 per month. Joanne has not remitted any of the income she earned in Germany priorto her arrival in the UK.Joanne resigned from her job at the end of November 2005. The company did not hold her to the three months noticestipulated in her contract, but still paid her for that period. In total, Joanne paid £4,200 in UK income tax under PAYEfor the tax tear 2005/06.Joanne also wishes to sell the shares she holds in a German listed company. The shareholding cost the equivalent of£3,500 in September 1986, and its current value is £21,500. She intends to sell the shares in March 2006 and toinvest the proceeds from the sale in the UK. Joanne has made no other capital disposals in the year.Prior to her leaving employment, Joanne investigated the possibility of starting her own business providing a Germantranslation service for UK companies, and took some advice on the matter. She paid consultancy fees of £5,000(excluding value added tax (VAT)) and bought a computer for £2,000 (excluding VAT), both on 23 October 2005.Joanne started trading on 1 December 2005. She made sales of £2,000 in December, and estimates that her saleswill rise by £1,000 every month to a maximum of £7,000 per month. Joanne believes that her monthly expenses of£400 (excluding VAT) will remain constant. Her year end will be 31 March, and the first accounts will be drawn upto 31 March 2006.Although Joanne has registered her business for tax purposes with the Revenue, she has not registered for VAT andis unsure what is required of her in this respect.Required:(a) State, giving reasons, whether Joanne will be treated as resident or non-resident in the UK for the year ofassessment 2005/06, together with the basis on which her income and gains of that year will be subject toUK taxation. (3 marks)

更多“2 Assume that today’s date is 1 July 2005.Jan is aged 45 and single. He is of Danish domicile but has been working in the United Kingdom since 1 May 2004and intends to remain in the UK for the medium to long term. Although Jan worked briefly in the UK in ”相关问题
  • 第1题:

    4 Assume today’s date is 15 May 2005.

    In March 1999, Bob was made redundant from his job as a furniture salesman. He decided to travel round the world,

    and did so, returning to the UK in May 2001. Bob then decided to set up his own business selling furniture. He

    started trading on 1 October 2001. After some initial success, the business made losses as Bob tried to win more

    customers. However, he was eventually successful, and the business subsequently made profits.

    The results for Bob’s business were as follows:

    Period Schedule D Case I

    Trading Profits/(losses)

    1 October 2001 – 30 April 2002 13,500

    1 May 2002 – 30 April 2003 (18,000)

    1 May 2003 – 30 April 2004 28,000

    Bob required funds to help start his business, so he raised money in three ways:

    (1) Bob is a keen cricket fan, and in the 1990s, he collected many books on cricket players. To raise money, Bob

    started selling books from his collection. These had risen considerably in value and sold for between £150 and

    £300 per book. None of the books forms part of a set. Bob created an internet website to advertise the books.

    Bob has not declared this income, as he believes that the proceeds from selling the books are non-taxable.

    (2) He disposed of two paintings and an antique silver coffee set at auction on 1 December 2004, realising

    chargeable gains totalling £23,720.

    (3) Bob took a part time job in a furniture store on 1 January 2003. His annual salary has remained at £12,600

    per year since he started this employment.

    Bob has 5,000 shares in Willis Ltd, an unquoted trading company based in the UK. He subscribed for these shares

    in August 2000, paying £3 per share. On 1 December 2004, Bob received a letter informing him that the company

    had gone into receivership. As a result, his shares were almost worthless. The receivers dealing with the company

    estimated that on the liquidation of the company, he would receive no more than 10p per share for his shareholding.

    He has not yet received any money.

    Required:

    (a) Write a letter to Bob advising him on whether or not he is correct in believing that his book sales are nontaxable.

    Your advice should include reference to the badges of trade and their application to this case.

    (9 marks)


    正确答案:
    (a) Evidence of trading
    [Client address]
    [Own address]
    [Date]
    Dear Bob,
    I note that you have been selling some books in order to raise some extra income. While you believe that the sums are not
    taxable, I believe that there may be a risk of the book sales being treated as a trade, and therefore taxable under Schedule D
    Case I. We need to refer to guidance in the form. of a set of principles known as the ‘badges of trade’. These help determine
    whether or not a trade exists, and need to be looked at in their entirety. The badges are as follows.
    1. The subject matter
    Some assets can be enjoyed by themselves as an investment, while others (such as large amounts of aircraft linen) are
    clearly not. It is likely that such assets are acquired as trading stock, and are therefore a sign of trading. Sporting books
    can be an investment, and so this test is not conclusive.
    2. Frequency of transactions
    Where transactions are frequent (not one-offs), this suggests trading. You have sold several books, which might suggest
    trading, although you have only done this for a short period - between one and two years.
    3. Length of ownership
    Where items are bought and sold soon afterwards, this indicates trading. You bought your books in the 1990s, and the
    length of time between acquisition and sale would not suggest trading.
    4. Supplementary work and marketing
    You are actively marketing the books on your internet website, which is an indication of trading.
    5. Profit motive
    A motive to make profit suggests trading activity. You sold the books to raise funds for your property business, and not
    to make a profit as such, which suggests that your motive was to raise cash, and not make profits.
    6. The way in which the asset sold was acquired.
    Selling assets which were acquired unintentionally (such as a gift) is not usually seen as trading. You acquired the books
    for your collection over a period of time, and while these were intentional acquisitions, the reasons for doing so were for
    your personal pleasure.
    By applying all of these tests, it should be possible to argue that you were not trading, merely selling some assets in
    order to generate short-term cash for your business.
    The asset disposals will be taxed under the capital gain tax rules, but as the books are chattels and do not form. part of
    a set, they will be exempt from capital gains tax.
    Yours sincerely
    A N. Accountant

  • 第2题:

    (b) Peter, one of Linden Limited’s non-executive directors, having lived and worked in the UK for most of his adult

    life, sold his home near London on 22 March 2006 and, together with his wife (a French citizen), moved to live

    in a villa which she owns in the south of France. Peter is now demanding that the tax deducted from his director’s

    fees, for the board meetings held on 18 April and 16 May 2006, be refunded, on the grounds that, as he is no

    longer resident in the UK, he is no longer liable to UK income tax. All of the company’s board meetings are held

    at its offices in Cambridge.

    Despite Peter’s assurance that none of the other companies of which he is a director has disputed his change of

    tax status, Damian is uncertain whether he should make the refunds requested. However, as Peter is a friend of

    the company’s founder, Linden Limited’s managing director is urging him to do so, stating that if the tax does

    have to be paid, then Linden Limited could always bear the cost.

    Required:

    Advise Damian whether Peter is correct in his assertion regarding his tax position and in the case that there

    is a UK tax liability the implications of the managing director’s suggestion. You are not required to consider

    national insurance (NIC) issues. (4 marks)


    正确答案:
    (b) Peter will have been resident and ordinarily resident in the UK. When such individuals leave the UK for a purpose other than
    to take up full time employment abroad, they normally continue to still be so regarded unless their absence spans a complete
    tax year. But, where someone intends to live permanently abroad or to do so for a period of at least three tax years, they may
    be treated as non-resident and non-ordinarily resident from the day after the date of their departure, if they can provide
    evidence to HMRC of that intention. Selling a residence in the UK and setting up home abroad will normally constitute such
    evidence. However to retain non-resident status the intention must actually be fulfilled, and visits to the UK must not exceed
    182 days in any tax year or average more than 90 days per year over a period of four tax years. Given that Peter would appear
    to have several company directorships in the UK, it is possible that he might fail to satisfy the 90 day average ‘substantial
    visits’ rule.
    Even if Peter is classed as non-resident, any remuneration earned in the UK will still be liable to UK income tax, and subject
    to PAYE, unless it is for duties incidental to an overseas employment, which is unlikely to be the case for fees paid to a nonexecutive
    director for attending board meetings. Thus, income tax should still be deducted from the fees under PAYE. Where
    PAYE should have been deducted from a director’s emoluments and it has not been, but the tax is nevertheless accounted
    for by the company to HMRC, then to the extent that the tax is not reimbursed by the director, he will be treated as receiving
    a benefit equivalent to the amount of tax.

  • 第3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:

     

  • 第4题:

    He told me that he ____ in Naples the previous year.

    A、has been working

    B、has worked

    C、had been working

    D、had been worked


    参考答案:C

  • 第5题:

    Since 1780, when the town’s first hat factory ______ in Danbury, Connecticut, the town has been a center for hat manufacturing in the United States.

    A、were established

    B、was establishing

    C、had been established

    D、was established


    参考答案:D

  • 第6题:

    _____has Mr. Clinton been a member of Greener China since he ____ to China?

    A、How soon, comes

    B、How often, got

    C、How long, came

    D、How far, arrived


    正确答案:C

  • 第7题:

    LA1A3330 两相故障时,故障点的正序电压UK1与负序电压UK2的关系为( )。

    (A)UK1 >UK2(B)UK1 =UK2(C)UK1 <UK2(D)UK1 =UK2=0

    答案:B
    解析:

  • 第8题:

    共用题干
    Breast Cancer Deaths Record Low

    The number of women dying from breast cancer has fallen to a record low by dropping under 12,000 a
    year for the first time since records began.
    The Cancer Research UK data showed that 11,990 women died in the UK in 2007.
    The previous lowest figure had been recorded in 1 97 1一 the year records began一after which it rose
    steadily year by year until the late 1980s.
    Professor Peter Johnson,Cancer Research UK's chief clinician,said,"It's incredibly encouraging to see fewer
    women dying from breast cancer now than at any time in the last 40 years,despite breast cancer being diagnosed
    more often."
    "Research has played a crucial role in this progress,leading to improved treatments and better management
    for women with the disease."
    " The introduction of the NHS(国民保健制度)breast screening program has also contributed as the
    earlier cancer is diagnosed,women are more likely to survive."
    Breast cancer is now the most common cancer in the UK with 45,500 women every year diagnosed with
    the disease一a 50% rise in 25 years.
    The number of deaths peaked in 1989,when 15,625 women died.It then fell by between 200 and 400
    deaths each year until 2004.
    There was a slight rise in 2005 and then two years of falls.
    Dr. Sarah Cant,policy manager at Breakthrough Breast Cancer,said,"It is great news that fewer women
    are dying from breast cancer and highlights the impact of improved treatments,breast screening and
    awareness of the disease."
    "However,there are still too many women affected and the incidence of the disease is increasing year by
    year.,,
    The rising rate of breast cancer diagnosis has been put down to a variety of factors including obesity
    (肥胖)and alcohol consumption.

    The rate of breast cancer diagnosis in the UK has been dropping.
    A:Right
    B:Wrong
    C:Not mentioned

    答案:B
    解析:
    在英国,2007年有11 990名女子死于乳腺癌。根据第二段中“The Cancer Research UK data showed that 11 ,990 women died in the UK in 2007”可知,2007年英国癌症研究中心的数据 显示,2007年美国妇女的死亡人数是11 990。虽然没有专门强调死亡是由乳腺癌所致,不过 根据句子中的“Cancer Research”和第一段的内容推断,此数字就是乳腺癌的死亡人数。因此 该推论是正确的。
    在英国,乳腺癌患者的死亡统计是从1971年开始的。根据文章第三段中“The previous lowest figure had been recorded in 1971一the year records began...”可知,先前的最低点是在1971 年,即开始作统计的那一年。由此得知该推论是正确的。
    在英国乳腺癌诊断的比率一直在下降。根据第四段中“…despite breast cancer being diagnosed more often."(······尽管被诊断为乳腺癌的病例越来越常见)可知,该论断是错误。
    该论断在文章中未提及。
    该论断在文章中未提及。
    该题句意为:2005年英国死于乳腺癌的女性人数少于2004年。根据倒数第四段中"There was。slight rise in 2005"(2005年人数略微上升)可以推断,该论断是错误的。
    最后一段中说obesity(肥胖)and alcohol consumption是诱发乳腺癌的原因,但未提及其 他疾病,因此选C0 put down to的意思是“归因于”。第3部分:概括大意与完成句子

  • 第9题:

    线路发生两相短路时,短路点处正序电压与负序电压的关系为()。

    • A、UK1>UK2
    • B、UK1=UK2
    • C、UK1<UK2
    • D、不确定

    正确答案:B

  • 第10题:

    线路发生两相短路时,短路点处正序电压与负序电压的关系为()

    • A、UK1>UK2
    • B、UK1=UK2
    • C、UK1
    • D、UK1≤UK2

    正确答案:B

  • 第11题:

    填空题
    Since 1945,the UK economy has experienced()decline rather than()decline.

    正确答案: relative,absolute
    解析: 暂无解析

  • 第12题:

    单选题
    The author intends to tell the readers that _____.
    A

    the United States is a wealthy country although poverty and crime exist there

    B

    crime has become a serious problem in the United States, although it is said to be a prosperous one

    C

    despite the fact that crimes have been increasing rapidly in the United States, it is a country of prosperity

    D

    in spite of stories about poverty and crime in the United States, it is prospering at an increasing rate


    正确答案: B
    解析:
    根据文章第一段第一句话可知,美国尽管繁荣,但还是存在贫困,而且还存在不断增长的高犯罪率。只有B项符合题意。

  • 第13题:

    6 Assume today’s date is 16 April 2005.

    Henry, aged 48, is the managing director of Happy Home Ltd, an unquoted UK company specialising in interior

    design. He is wealthy in his own right and is married to Helen, who is 45 years old. They have two children – Stephen,

    who is 19, and Sally who is 17.

    As part of his salary, Henry was given 3,000 shares in Happy Home Ltd with an option to acquire a further 10,000

    shares. The options were granted on 15 July 2003, shortly after the company started trading, and were not part of

    an approved share option scheme. The free shares were given to Henry on the same day.

    The exercise price of the share options was set at the then market value of £1·00 per share. The options are not

    capable of being exercised after 10 years from the date of grant. The company has been successful, and the current

    value of the shares is now £14·00 per share. Another shareholder has offered to buy the shares at their market value,

    so Henry exercised his share options on 14 April 2005 and will sell the shares next week, on 20 April 2005.

    With the company growing in size, Henry wishes to recruit high quality staff, but the company lacks the funds to pay

    them in cash. Henry believes that giving new employees the chance to buy shares in the company would help recruit

    staff, as they could share in the growth in value of Happy Home Ltd. Henry has heard that there is a particular share

    scheme that is suitable for small, fast growing companies. He would like to obtain further information on how such

    a scheme would work.

    Henry has accumulated substantial assets over the years. The family house is owned jointly with Helen, and is worth

    £650,000. Henry has a £250,000 mortgage on the house. In addition, Henry has liquid assets worth £340,000

    and Helen has shares in quoted companies currently worth £125,000. Henry has no forms of insurance, and believes

    he should make sure that his wealth and family are protected. He is keen to find out what options he should be

    considering.

    Required:

    (a) (i) State how the gift of the 3,000 shares in Happy Home Ltd was taxed. (1 mark)


    正确答案:
    (a) (i) Gift of shares
    Shares, which are given free or sold at less than market value, are charged to income tax on the difference between the
    market value and the amount paid (if any) for the shares. Henry was given 3,000 shares with a market value of £1 at
    the time of gift, so he was assessed to income tax on £3,000, in the tax year 2003/04.

  • 第14题:

    6 Andrew is aged 38 and is single. He is employed as a consultant by Bestadvice & Co and pays income tax at the

    higher rate.

    Andrew is considering investing in a new business, and to provide funds for this investment he has recently disposed

    of the following assets:

    (1) A short leasehold interest in a residential property. Andrew originally paid £50,000 for a 47 year lease of the

    property in May 1995, and assigned the lease in May 2006 for £90,000.

    (2) His holding of £10,000 7% Government Stock, on which interest is payable half-yearly on 20 April and

    20 October. Andrew originally purchased this holding on 1 June 1999 for £9,980 and he sold it for £11,250

    on 14 March 2005.

    Andrew intends to subscribe for ordinary shares in a new company, Scalar Limited, which will be a UK based

    manufacturing company. Three investors (including Andrew) have been identified, but a fourth investor may also be

    invited to subscribe for shares. The investors are all unconnected, and would subscribe for shares in equal measure.

    The intention is to raise £450,000 in this manner. The company will also raise a further £50,000 from the investors

    in the form. of loans. Andrew has been told that he can take advantage of some tax reliefs on his investment in Scalar

    Limited, but does not know anything about the details of these reliefs

    Andrew’s employer, Bestadvice & Co, is proposing to change the staff pension scheme from a defined benefit scheme

    to which the firm and the employees each contribute 6% of their annual salary, to a defined contribution scheme, to

    which the employees will continue to contribute 6%, but the firm will contribute 8% of their annual salary. The

    majority of Andrew’s colleagues are opposed to this move, but, given the increase in the firm’s contribution rate

    Andrew himself is less sure that the proposal is without merit.

    Required:

    (a) (i) Calculate the chargeable gain arising on the assignment of the residential property lease in May 2006.

    (2 marks)


    正确答案:

     

  • 第15题:

    3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans to

    expand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell her

    shares back to the company. Once the purchase of her shares has taken place, the company intends to establish a

    number of branches overseas and acquire a shareholding in a number of companies that are resident and trade in

    overseas 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 be

    between 23% and 42%.

    – There may or may not be a double tax treaty between the UK and the overseas countries in which the companies

    are 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 companies

    will 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 will

    receive for her shares; (7 marks)


    正确答案:

     

  • 第16题:

    线路发生两相短路时,短路点处正序电压与负序电压的关系为()。

    A.UK1>UK2

    B.UK1=UK2

    C.UK1<UK2


    参考答案:B

  • 第17题:

    Lao Lin has been working in the countryside for a long time, so he _______ farm work.

    A、used to

    B、is used to

    C、use

    D、use to


    正确答案:B

  • 第18题:

    共用题干
    第二篇
    Around 45%of the UK's carbon dioxide emissions come from the energy people use every day-at home and when they travel.In order to generate that energy,fossil fuels(coal oil,and gas)are burnt,and these produce greenhouse gases-in particular carbon dioxide(CO2).Car emissions are a major problem, but the truth is that more CO2 comes from the energy used at home.The average household creates around
    five and a half tonnes of CO2 a year,and it is the same CO2 that is changing the climate and damaging the environment.
    CO2 and various other gases wrap the earth in an invisible blanket helping to prevent heat from escaping.Without this greenhouse effect,the average temperature on Earth would be around-18℃, compared with the current average of around+15℃.The composition of this blanket of gases has remained relatively constant for many thousands of years.However,since the industrial revolution began around 200 years ago,people have been burning increasing amounts of fossil fuels,thus releasing more CO2 and other greenhouse gases in the process.This has increased the heating effect of the blanket,trapping more of the sun's energy inside the Earth's atmosphere in turn the Earth's temperature has increased more rapidly in a shorter period of time than it has for thousands of years.
    In 2008,the total UK CO2 emissions were 533 million tonnes.27%(144 million tonnes)of those emissions came from the energy used to heat,light,and power homes.Transport emissions caused by passenger cars,buses and motorcycles accounted for a further 16%(87 million tonnes)of the UK's CO2 emissions.These figures show that a significant amount of CO2 results from ordinary citizens carbon footprint in their daily activities and lifestyle.
    The effects of climate change can be seen all around us.Weather patterns are becoming more and more fractured and uncertain,and over the last century trends in warm weather have become increasingly common.In the UK in the last 40 years,winters have grown warmer,with much heavier rainfall.One of the clearest shifts over the last 200 years is towards summers that are hotter and drier,causing pervasive(普遍的)water shortages.Recent years have been the hottest since records began and during August 2003,the hottest ever outdoor temperature in the UK was recorded-38.5℃.

    Which of the following is the best title for the passage?
    A:Ways of reducing the UK's CO2 emissions.
    B:UK citizen's carbon footprint.
    C:The effect of industry on climate change in the UK.
    D:Changes in weather patterns in the UK.

    答案:B
    解析:
    本文以英国的情况为例,主要讲述了人们在日常生活中排出大量二氧化碳气体及这种情次对地球环境的影响。文章以英国二氧化碳气体的排放来源展开论述,指出由于人们活动消耗能源,使得大气中产生大量的二氧化碳。并通过具体数据来论述人类的日常活动排放的大量二氧化碳及其对气候所产生的不良影响。故本题选C。
    由文章第一段第三句和第四句话的内容可知,家庭排放的二氧化碳气体占据二氧化碳排放量的主要部分,比汽车排放的多,故选C。
    由文章第三段中的内容可知,2008年,在英国有16%的二氧化碳气体来自于交通工具的排放,这和D项意思相符,故选D。
    文章第四段第三句话中提到,在过去40年里,英国的冬天变得更暖,降雨也更加猛烈, A、B、D三项的内容文中均未提及,故选C。
    由第36题的解析可知,文章主要围绕在英国人们日常生活所排放的大量二氧化碳气体及其对气候的影响来展开。故本题最佳答案为B。

  • 第19题:

    资料:Economic performance is improving in most of the world's leading economies but is still short of a self-sustaining upswing, the Organization for Economic Cooperation and Development said on Wednesday.
    In an update to its economic forecasts, the Paris-based international organisation representing advanced economies said that more private sector investment was needed for the expansion to endure, for wages to rise sustainability and for inequalities to be tackled.
    Although all leading economies are now recording positive growth, Catherine Mann, the OECD's chief economist, urged governments to “curb your enthusiasm [ because] strong and sustained medium-term global growth is not yet secured”.
    The OECD's economic outlook shows upgrades to the 2017 growth forecasts in China, Russia and Europe excluding the UK with the world outlook also appearing stronger in 2018.
    World growth should rise from a low of 3.1 per cent in 2016, to 3.5 per cent this year and 3.7 per cent in 2018, the OECD forecast, with the US, the Eurozone, Brazil and Russia contributing most to the improved global outlook.
    China's predicted growth rate of 6.8 per cent in 2017 and 6.6 per cent in 2018 has been revised higher by 0.2 percentage points in both years and although India's growth rate has been revised down, reflecting adjustment to its new goods and services tax, it is likely to remain the fastest growing large economy in the world.
    Only the UK, which remains embroiled in Brexit negotiations, has a deteriorating outlook. Responding to the OECD's forecast that the British economy will be the slowest growing in the Group of Seven in 2018 having been near the top of the league table in 2016, the British Treasury said it was not complacent.

    According to the passage,which one of the following statement is true?

    A.The Russia’s 2017 economic growth forecast has been revised higher.
    B.The leading economies have achieved sustainable long-term growth.
    C.The OECD is not optimistic about China's economic growth.
    D.India's economic growth forecast have been upgraded.

    答案:A
    解析:
    本题考查细节理解。
    【关键词】 which one of the following statement is true
    【主题句】第3、4、6自然段.Although all leading economies are now recording positive growth, Catherine Mann, the OECD’s chief economist, urged governments to “curb your enthusiasm [ because] strong and sustained medium-term global growth is not yet secured”.尽管所有主要经济体如今都记录的正增长,但经合组织首席经济学家凯瑟琳?曼(Catherine Mann)敦促各国政府“抑制激情,(因为)强劲且持续的中期全球增长尚未得到保障”。
    The OECD’s economic outlook shows upgrades to the 2017 growth forecasts in China, Russia and Europe excluding the UK with the world outlook also appearing stronger in 2018.经合组织在经济展望中,上调了对中国、俄罗斯和欧洲(除英国外)2017年的增长预测,2018年的全球经济前景似乎也更加强劲。
    China’s predicted growth rate of 6.8 per cent in 2017 and 6.6 per cent in 2018 has been revised higher by 0.2 percentage points in both years and although India’s growth rate has been revised down, reflecting adjustment to its new goods and services tax, it is likely to remain the fastest growing large economy in the world.中国在2017年和2018年的预期增速分别达到和,分别被上调0.2个百分点。虽然印度的增长率遭到下调(反映根据该国新的商品及服务税作出的调整),但印度很可能仍是全球增长最快的大型经济体。
    【解析】题干意为“下列哪一项是正确的?选项A意为“俄罗斯2017年经济增长预测被上调”;选项B意为“发达经济体已经获得长期可持续增长”;选项C 意为“经合组织对中国经济增长不乐观”;选项D意为“印度经济增长被上调”。根据主题句可知,选项B、C、D与题意不符,故选项A正确。

  • 第20题:

    Since 1945,the UK economy has experienced()decline rather than()decline.
    relative;absolute

  • 第21题:

    两相故障时,故障点的正序电压UK1与负序电压UK2的关系为()。

    • A、UK1>UK2;
    • B、UK1=UK2;
    • C、UK1<UK2;
    • D、UK1=UK2=0。

    正确答案:B

  • 第22题:

    线路发生两相短路时,短路点处正序电压与负序电压的关系是()。

    • A、UK1=UK2
    • B、UK1>UK2
    • C、UK1<UK2
    • D、不确定

    正确答案:A

  • 第23题:

    单选题
    Hannah finished building her new all-purpose projects room last year, and she has been working in the room ever since.
    A

    and she has been working in the room ever since

    B

    and since that time she has worked there

    C

    where always since she works

    D

    she has been working in that room ever since

    E

    and since then is working there


    正确答案: A
    解析:
    原句正确。C,D,E项语法不正确。B项没有A项恰当流畅。