PAPER IIA UNITED KINGDOM OPTION

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1 THE ADVANCED DIPLOMA IN INTERNATIONAL TAXATION June 2008 PAPER IIA UNITED KINGDOM OPTION ADVANCED INTERNATIONAL TAXATION TIME ALLOWED 3¼ HOURS You should answer FOUR out of the seven questions. Each question carries equal marks. Start each answer on a new sheet of paper. All workings should be made to the nearest month and pound unless the question requires otherwise. Marks are specifically allocated for presentation. Unless the question specifically requires you to discuss EC aspects, you should assume that all the countries mentioned are not members of the EC and that you do not need to discuss EC aspects in your answer.

2 1. You are a tax manager in an advisory firm. Your partner has arranged a meeting with the finance director of a Japanese-headquartered multinational group which is considering the commencement of business activities in the United Kingdom. The group s main activity is the development and sale of pharmaceutical products and they are particularly attracted to the United Kingdom by the availability of high calibre research scientists working in the field. You have been asked to brief your partner on the taxation issues which should be discussed. He has made you aware of the following points: 1) The company is determined to ensure that it attracts a high quality workforce and is looking for ways of giving the employees a stake in the business. The Japanese parent company has a stock option scheme and is willing to allow non- Japanese employees to participate therein but is equally willing to consider them acquiring a stake in the United Kingdom business either through stock options or the issue of free shares which would be forfeit if they were to leave the company. 2) The senior management at the outset will be sent from the Japanese head office with the expectation of serving in the United Kingdom for two or three years while local management is developed. They will remain employees of the Japanese parent company which will continue to pay their salaries and will also pay for their accommodation costs in the United Kingdom, as well as holiday visits back to Japan. 3) The finance director wants to know your suggestions on the extent to which the business should be funded by debt as opposed to equity. There will be some significant fixed asset expenditure in the first year or so, including buildings with specialist fixtures and sophisticated plant and equipment. 4) The Group s normal policy when entering a new country is to set up a branch of a Japanese company rather than incorporate a local company. This is because a branch is generally easier to terminate if the business does not live up to expectation. If profits start to be made within three years of commencement, this is seen as a positive sign and a local company would be incorporated to take over the business at that stage. 5) Although the company will be undertaking a significant amount of research work, it will also make use of some products already developed by the Group, with ownership of the relevant intellectual property being held by a group company incorporated in Labuan (Malaysia) where, in lieu of tax, it pays an annual fee of MNR 20,000. Payment of royalties for this intellectual property is seen as a possible way of extracting operating profit from the United Kingdom. 6) The finance director has heard that there are tax incentives available for undertaking research and development in the United Kingdom and wishes to know more about these. He has commented that some of the more basic work on the research programmes may be subcontracted to other group companies in lower cost jurisdictions in Eastern Europe. 7) The company s products are likely to be sold primarily in United States dollars and the audit partner has indicated that that will be the company s functional currency. The finance director wishes to know whether United Kingdom tax can be calculated using that currency. You are required to prepare a briefing paper for your partner explaining the relevant United Kingdom tax issues. (25) D/ADIT/EP/II UK 2

3 2. You have been asked to speak at a conference of senior HR executives who have responsibility for looking after internationally mobile employees. The conference organisers have advised you that the target audience has expressed a particular interest in the following issues: They would like to receive an explanation of the concepts of residence and ordinary residence for individuals as they apply for United Kingdom tax purposes, with some understanding of the legal bases for these as well as the practice of HM Revenue & Customs. They would also like to understand the ways in which residence and ordinary residence are important in determining liability to Income Tax and Capital Gains Tax. They would like to understand how expatriate employees are subject to National Insurance in the United Kingdom, covering both those who are leaving the United Kingdom to work abroad and those who are coming to the United Kingdom to work. They have asked that you explain the circumstances under which employees can contribute to United Kingdom pension schemes while working overseas. You are required to prepare notes for your conference talk. (25) 3. Following the introduction of Capital Gains Tax in 1965, significant tax avoidance opportunities were identified using trusts resident outside the United Kingdom. Various legislative provisions have been introduced over the years to counter such avoidance. You are a tax manager in a legal firm which acts for a number of high net worth individuals. You have been asked to deliver a talk to your colleagues explaining the provisions which govern the Capital Gains Tax charge in respect of non-united Kingdom resident trusts, their settlors and beneficiaries. You are required to prepare notes for your talk. You should include an explanation of the determination of the residence of trusts. (25) 4. Decisions of the Court of Justice of the European Communities have had an increasing effect on the United Kingdom s tax system in recent years. You are required to identify five significant tax cases referred to the CJEC from the United Kingdom, explaining in respect of each case the point at issue, the decision and the reasoning and explaining the influence of the case on the United Kingdom s tax system. At least one but not more than two of the cases selected should relate to VAT. (25) D/ADIT/EP/II UK 3

4 5. A plc recently undertook an acquisition of the B group. This was effected as follows: 1) A plc borrowed $600 million from a UK resident bank. 2) A plc and a UK subsidiary, C Ltd, formed an entity (D) under the laws of country B. 3) A plc contributed cash of $200m as capital to D and loaned the remaining $400m to D, such loan bearing interest at a fixed rate of 6%. After this D was owned 99% by A plc and 1% by C Ltd. 4) D acquired B from a third party using the cash of $600 million. A plc and C Ltd are UK tax resident companies and both prepare their accounts in sterling. B is a company formed under the laws of country B. B is a holding company and has two subsidiaries, E and F, both of which undertake trading activities in country B. The shareholders of B before the acquisition were non-uk resident individuals. Interest is paid by D through the receipt of dividends from B, which in turn receives dividends from E and F. D is not a legal person and was formed under the laws of country B through A plc and C Ltd signing an agreement in front of a notary to carry on business together via D. A plc and C Ltd have capital accounts according to the agreement and these accounts are increased or decreased as profits and losses are made by D, such increases and decreases being made in accordance with the percentage of capital contributed to D. A plc has limited liability in relation to the debts of D but C Ltd does not. You are required to analyse the UK tax implications of the above structure and transactions, covering issues associated with setting up the structure as well as the ongoing UK tax issues of the structure. (25) D/ADIT/EP/II UK 4

5 6. H Ltd, a UK tax resident company, directly owns 100% of I, J and K. I is a non-uk tax resident company that carries on a group financing activity, lending funds to companies that are not resident in the same country as I. I is a controlled foreign company ( CFC ) for UK tax purposes and avoids an apportionment through pursuing an Acceptable Distribution Policy ( ADP ) each year. J is also a non-uk tax resident company that owns three subsidiaries, L, M and N, all of which are resident in the same country as J. J files a consolidated tax return reflecting the results of itself together with L, M and N. K is also a non-uk resident company that owns two subsidiaries, O and P, neither of which is resident in the same country as K. J, K, L, M, N, O and P are either not CFCs for UK tax purposes or, alternatively satisfy the exempt activities test each year. In November 2007 the companies paid the following dividends: I (100), J (1,000), K (1,000), L (150), M (250), O (200), P (500). The dividends paid by K, O and P were specified as paid out of their profits for the year ending 31 December 2007, whilst none of the other dividends were specified in any way. The profits and taxes of the various companies were as follows: Year ended 31 December 2007 Profit/(loss) before tax Tax per accounts Profit after tax Tax per tax return I J K L M N O P 140 1,400 1, (100) (40) (600) - (150) (50) - (200) (100) , (100) Year ended 31 December 2006 Profit before tax Tax per accounts Profit after tax Tax per tax return I J K L M N O P 110 1,000 1, (30) (10) (300) - (250) (20) - (300) (50) , (30) The profits of J and K include dividends received from subsidiaries. 1) You are required to describe in general terms how dividends received by a UK resident company from a non-uk resident company are taxed, including how relief for foreign taxes (including those paid at a rate higher than the UK Corporation Tax rate) is given in relation to such dividends. (10) 2) In the above scenario, compute the UK tax payable by H Ltd in relation to the dividends received from I, J and K in the year ended 31 December 2007, including the double tax relief and eligible unrelieved foreign tax available (15) Total (25) D/ADIT/EP/II UK 5

6 7. 1) A, a company resident in Country A, recently transferred the shares of C Ltd to B Ltd in exchange for the issue by B Ltd to A of shares and a sterling denominated loan note. Therefore after the transfer B Ltd had a debt owed to A on which it paid interest. B Ltd and C Ltd are UK resident companies. The structure after the transfer is as follows: A interest B Ltd loan C Ltd A is not taxed on the interest income received from B Ltd as, under the tax law of Country A, B Ltd is regarded as fiscally transparent and therefore A does not consider that the loan note exists for country A tax purposes. You are required to describe the UK tax implications of the above structure, including the deductibility of interest paid by B Ltd to A and also the impact of the double tax treaty between Country A and the UK (assuming this treaty is similar to the OECD Model Convention). (15) 2) Your client recently phoned to find out how the UK controlled foreign companies ( CFC ) rules work. You are required to respond to your client explaining how the CFC rules operate and what exemptions exist from a charge to UK tax under these rules. (10) Total (25) D/ADIT/EP/II UK 6

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