ATX Question Grid
ATX Question Grid
(c)Trading loss (Exhibits 1 and 2)For the purposes of this part (c) you should IGNORE terminal
loss relief and national insurance contributions.(i)Calculate Hiromi’s budgeted trading loss for the
Hiromi tax year 2023/24 and state how the loss can be relieved.(ii)Using the loss calculated in part (i):(1)
Explain, with supporting calculations, the tax savings which would result from the following two
alternatives:– relieving the loss as soon as possible assuming that NO relief is claimed in respect of
the tax year 2023/24;– relieving the loss in the future.(2) Set out the matters we should draw to
Hiromi’s attention in order to help her decide on how to relieve the loss.
(d)When HKR Ltd owns the business (Exhibit 2)– Explain with supporting calculations, the tax
implications for HKR Ltd and Hiromi of HKR Ltd paying a dividend of £7,000 in the tax year 2025/26.–
State the matters you would draw to Hiromi’s attention in relation to the requirement for HKR Ltd to
maintain and retain the records relating to its business activities
(a) Explain the corporation tax treatment for Silves Ltd in the year ending 31 March 2023 in relation to
the acquisition of each of the two assets.
(b)(i) Explain, by reference to the relief(s) available for the forecast trading loss, why it will be
ATX-UK June 2023 (23/24
4 advantageous for Evora Ltd to commence trading in Salema through a permanent establishment (PE)
syllabus)
rather than an overseas subsidiary company.
(b)(ii) State the tax consequences for Evora Ltd of making an election to exempt the profits of
Evora Ltd
overseas PEs from UK corporation tax, and advise the company whether or not it will be beneficial to
make this election on the basis of the company’s current forecast results, and its future plans.
(c) Explain how the following items will be reported on Evora Ltd’s value added tax (VAT) return for
the quarter ending 30 June 2023:
.the services purchased from the overseas legal firm; and
.the goods acquired from the overseas supplier.
State how these transactions will affect the amount of VAT payable declared on this return.
(a) Explain the capital gains tax and inheritance tax (IHT) implications of the proposed gift of the
painting to Violette on 1 August 2023.
(b) In relation to Anya’s proposed gift of the Chaski Ltd shares to Cara on 1 September 2023:
(i) Advise on the availability to Anya of gift holdover relief, and any consequences for Cara of this relief
being claimed.
Anya
(ii) Advise on the availability of business property relief in calculating the IHT liability on this gift as a
result of Anya’s death, and any additional conditions for Cara attaching to this relief.
(c) Calculate the reduction in Anya’s post-tax income for the tax year 2023/24 as compared with the
tax year 2022/23, on the assumption that she gifts all of her shares in Chaski Ltd to Cara as planned.
(a)Rij Ltd – corporate matters (Exhibit 1)Prepare a memorandum for the client file which should
address the following issues.(i)Post-tax cost of the planned researchI can confirm that Rij Ltd is a small
or medium-sized enterprise for the purposes of the relief available in respect of research and
development costs and that the research to be carried out will qualify for any additional tax
deductions available.– Calculate the post-tax cost of the budgeted research and development
expenditure of £150,000.You should ignore both the interest payable on the loan and national
insurance contributions.(ii)Tax relief in respect of the interest payable on the loan– Explain, by
reference to the loan relationships rules, how much of the interest payable on the proposed
loan will be deductible for corporation tax purposes for the year ending 30 September
2024.(iii)Relieving Sta Ltd’s trading loss brought forward– Explain the extent to which Sta Ltd’s
budgeted loss carried forward, as at 1 October 2023, can be relieved against the profits of Sta Ltd
and/or Rij Ltd for the year ending 30 September 2024 and summarise your findings.(iv)Refund of
corporation tax– Summarise the matters which we should consider in relation to the refund
received by Rij Ltd.
Rij Ltd
Ella – personal matters (Exhibit 2)Prepare paragraphs to be included in a letter to Ella which should
address the following issues.(i)Sale of commercial building in the country of BureeaI can confirm that
Ella is domiciled in the UK. She was non-UK resident for the period from 6 April 2020 to 5 April 2023.
From 6 April 2023 to 30 September 2023, Ella has no ties to the UK for the purposes of determining
her tax residence status. In addition, Ella’s only income which will be subject to UK income tax in the
tax year 2023/24 will be her salary from Sta Ltd.
– Explain, by reference to Ella’s residence status for the tax year 2023/24, why the sale of the
commercial building would NOT result in a UK capital gains tax (CGT) liability if Ella were able to sell
the building prior to her return to the UK.Your analysis of Ella’s tax residence status will need to
ATX-UK September 2023
5 take account of the workings of the split year basis.– Calculate the CGT which would be saved as a
(23/24 syllabus)
result of this strategy.
(ii)Inheritance tax (IHT) payable in respect of the gift of land– Calculate the IHT payable by Ella as a
result of the death of her grandmother.You should include an explanation of the relevance of the
gift to Ella’s brother on 1 March 2014.
(a)(i) Explain whether or not business asset disposal relief will be available on the sale of the
warehouse; and
(a)(ii) Calculate Logan’s total after-tax proceeds (before taking account of the impact of his additional
pension contribution) from the sale of the warehouse and fixed machine.
Logan (b) Calculate, with supporting explanations, the reduction in Logan’s income tax liability for the tax
year 2023/24 as a result of investing the additional £28,000 cash into his personal pension scheme.
(c)(i) State, with reasons, the additional information which will be required to determine whether the
conditions for the new UK cottage to qualify as a furnished holiday letting are satisfied.
(c)(ii) Explain ONE specific tax advantage which would be relevant for Logan if the cottage does qualify
as a furnished holiday letting.
(a) Explain the availability of the nil rate band and residence nil rate band when calculating the value
of Mucuna’s chargeable estate on death.
(b) Calculate Sieva’s after-tax proceeds in respect of the planned sale of her shares in Lima Ltd to
Roman, on the assumption that any available relief(s) are claimed. Briefly state the reason for the rate
Sieva
of capital gains tax which will be charged on this sale.
(c) Explain how leaving the flat rate scheme would affect the way in which the amount of value added
tax (VAT) payable by Sieva to HM Revenue and Customs (HMRC) for each VAT period is calculated.
(a)Becoming tax advisers to JakeI have not identified any threats to compliance with the fundamental
principles of professional ethics which would arise as a result of becoming tax advisers to Jake.–
Explain why it is important that we contact Jake’s previous tax advisers.– State any other actions we
should take before we agree to become Jake’s tax advisers.
ignore the alternative plan for the use of the Yak Building and simply assume that the whole of the
Yak Building will be used for the purposes of carrying on Jake’s unincorporated business. You should
also ignore value added tax (VAT).(i)Insurance proceeds available for investment in the business(1)On
the assumption that the construction of the Yak Building will be completed and paid for on 1
February 2024:– explain the relief available to Jake in respect of the chargeable gain resulting
from the destruction of the Vol Building.(2)On the assumption that Jake claims the relief you have
identified in (1), and will have total income in the tax year 2023/24 of £30,000:– calculate the
amount of post-tax insurance proceeds which will be available, after the construction of the
Yak Building, for investment in the new business.(ii)Tax deductions in respect of the expenditure to
be incurred– Explain when, if at all, Jake will be able to obtain a tax deduction for the costs he is likely
to have incurred in respect of visiting potential customers.– Explain the tax deductions which will be
available in Jake’s first trading period ending on 30 April 2025 in respect of the costs of:– the
Jake
that the alternative plan for the use of the Yak Building is followed.I can confirm that the supplies to
be made by Jake’s unincorporated business will be wholly standard rated for VAT purposes. However,
due to the application of the capital goods scheme, Jake’s ability to recover the full £67,000 of input
tax over the life of the building will be restricted unless he opts to tax the building.– Calculate the
maximum amount of ADDITIONAL input VAT which Jake could recover if he were to elect to
opt to tax the Yak Building on 1 May 2024. Your calculations should indicate the years in which
the input tax would be recovered.
ATX-UK December 2023
6 (c)Sale of shares in POL Ltd (Exhibit 2)On the assumption that Jake sells the POL Ltd shares in the tax
(23/24 syllabus)
year 2024/25 for £470,000, and that his aunt dies between now (1 January 2024) and 31 December
2026 (i.e. within seven years of the potentially exempt transfer):– Explain, without carrying out any
calculations, Jake’s potential liability to inheritance tax (IHT) at the time of the sale of the shares and
on the subsequent death of his aunt. – Calculate the chargeable gain resulting from the sale,
before the deduction of any available reliefs, and explain whether or not the following reliefs
would be available:– business asset disposal relief; and – rollover relief.– Explain the
relief which would be available in respect of any IHT payable following the death of Jake’s aunt.
(a) In relation to Rabo Ltd’s sale of the freehold factory: − Calculate the a er-tax proceeds; and −
Explain how the base cost of this factory is calculated.
(b) (i) Explain the maximum possible amount of Rabo Ltd’s trading loss for the year ending 31
December 2023 which can be transferred to Morada Ltd; and
(b) (ii) Explain the tax consequences for Rabo Ltd of using some, or all of the loss itself, and explain
Rabo Ltd
any potential issues associated with such a course of action.
(c) Explain with supporting calculations:
. The rollover relief and capital allowances which may be claimed as a result of the planned capital
acquisitions on 1 June 2024; and. The total corporation tax savings which these will give rise to in the
year ending 31 December 2024.
(a) Assuming that Pinto does not satisfy any of the automatic tests in relation to tax residence,
explain whether or not he will be resident in the UK for tax purposes in the tax year 2023/24.
(b) Explain, by reference to Pinto’s tax residence status, why the sale of his house in the UK on 30 April
Pinto
2022 will have been subject to UK capital gains tax, and calculate the chargeable gain arising. You
should include an explanation of any relief(s) available. (c) Calculate Pinto’s property income, after all
taxes, in respect of his house in Vicia for the tax year 2024/25.
preparing for a meeting with Rosetti. When carrying out this work you should note that the Lark Ltd
group claims all possible tax deductions and deferrals in respect of both tangible and intangible assets
as soon as possible.The memorandum should cover the following matters:(i)Sale of STV Ltd (Exhibit
1)You should ignore value added tax (VAT) when carrying out this task (i).(1) Tax implications of the
saleIn respect of Option 1:– Explain the corporation tax implications for Lark Ltd of a sale of the
shares.In respect of Option 2:– Explain the corporation tax implications for STV Ltd and the
stamp duty land tax implications of a sale of the Strick Building; and – Calculate the taxable profit
resulting from a sale of the ‘S’ trademark.(2) In order to assist Rosetti in deciding on which option to
proceed with:– Prepare calculations to show which option would generate the greater amount
of post-tax proceeds for Lark Ltd.– In respect of both options, set out any other tax and/or
commercial matters directly related to this proposed sale which we should draw to Rosetti’s
group VAT registration and that the UK tax resident companies in the group make standard rated
supplies only. However, Rosetti will need to resolve certain administrative issues before the
application can be finalised, such that the group registration will not be in place until 1 May 2024.–
Explain which of the companies in the Lark Ltd group could be included within a group VAT
Lark Ltd group registration with Lark Ltd.– On the assumption that the sale of STV Ltd is carried out in
accordance with Option 2, explain why the sale of business assets would NOT qualify as a transfer of
a going concern (TOGC) and, consequently, whether or not STV Ltd would be required to charge VAT
on the sale of the Strick Building to VAR Ltd.
(iii)Reducing the corporation tax payable by the group companies (Exhibit 2)Pricing strategy– Explain
the corporation tax implications for the Lark Ltd group of adopting the pricing strategy suggested by
Rosetti.Strategy suggested by business adviserI have reviewed this strategy and concluded that it
would fall within the general anti-abuse rule (GAAR).– Distinguish between tax evasion and tax
avoidance and state the purpose of the GAAR.– Explain why the GAAR would apply to the
strategy suggested by Rosetti’s business adviser.(b)Rosetti – gifts of ordinary shares in Lark Ltd
ATX-UK June 2024 (24/25 (Exhibit 3)Write a memorandum for Rosetti’s client file. When carrying out this work you should
7 assume that:– On 1 May 2024 the market value of 1,500 shares in Lark Ltd will be £27,000.– Rosetti is
syllabus)
a higher rate taxpayer and business asset disposal relief will be available in respect of the gifts.For
each of the two proposed gifts:– Explain whether or not gift holdover relief will be available.–
Calculate Rosetti’s capital gains tax (CGT) liability (if any), and the recipients’ CGT base cost in
the shares received.
(a)(i) Explain the relief available in respect of the lifetime gift made by Fiera to Perla, as a result of
Fiera’s death.
(a)(ii) Calculate the amount of Risa’s inheritance from Fiera’s death estate, after deducting any
inheritance tax payable. You should include an explanation of the relief available to reduce the
taxable value of the estate.
(b)(i) State the options available to Risa to relieve her share of the loss of Perro & Co for the year
Risa
ended 31 March 2024, on the assumption that she does not wish to carry any of this loss forward.
(b)(ii) Explain which of the available options for relieving the loss (as identified in (i) above) will result
in the highest income tax saving for Risa, and calculate the amount of this tax saving.
(c) Explain how income tax relief will be given for the interest payable on the loans taken out by Risa
on 6 April 2024, and calculate the total amount of any income tax saving for the tax year 2024/25 in
respect of this relief.
(a)(i) Calculate the amount of UK income tax Iker would have to pay in respect of his overseas
property income for the tax year 2024/25 on the assumption that it will be taxed on the arising basis.
(ii) Explain whether or not Iker is eligible to claim for his overseas property income to be taxed on the
remittance basis.
Iker status, why the disposal of Painting 1 will be subject to UK capital gains tax (CGT); and (ii) Explain
whether it would be preferable for Iker to gift Painting 2 on 1 April 2025 or 1 May 2025 in order to
(c) Calculate the additional disposable income available to Iker for the tax year 2025/26 as a result of
being provided with living accommodation by Laudio Ltd. You should include an explanation of your
treatment of the expenditure on the construction of the conservatory.