CTA Examination – Awareness – Module C – Corporation Tax Question 1 Augmented profits: Taxable total profits FII Income (10/9 x 22,500) Total augmented profits Total taxable profits Tax at main rate @ 24% Less marginal relief: 1/100 x (1.5m - 340k) x 315,000/340,000 1/100 x 1,160,000 x 0.9264 = Corporation tax liability 315,000 25,000 340,000 315,000 75,600 (10,746) 64,854 Question 2 CT is paid on a chargeable accounting period which cannot exceed 12 months. The company will therefore have 2 chargeable accounting periods (CAP): First period 1 September 2011 to 31 August 2012 Second period 1 September 2012 to 31 December 2012 CT is paid 9 months and one day after the end of each CAP so by 1 June 2013 and 1 October 2013 Filing deadlines are 1 year from end of accounting period so by 31 December 2013 Question 3 Trading losses can only be set against profits of a group company within the same year. As company overlaps, need to work out the overlap period PC account TU Ltd 1 April 31 March 1 January 31 December Overlap of 9 months = loss 310,000 x 9/12 = 232,500 TU could transfer loss to PC to max of 232,500 Question 4 Chargeable gain: Proceeds of sale Less acquisition cost (substituted with original cost) Chargeable gain 610,000 210,000 400,000 Disposals between members of the same group are on a no gain no loss basis. Therefore the original base cost of Arto would be used in the CGT computation regardless of how much Teo paid for the warehouse. Question 5 Only parts of the expenditure will qualify for relief: Only 50% of the staff costs is attributable to research and development so 48,000/2 is available for relief = £ 24,000 Computer hardware is not qualifying expenditure Laboratory chemicals qualify and so do specialist software as both are attributable to the research project. Additional relief: Staff costs Laboratory chemicals Specialist software 24,000 34,000 18,000 76,000 Relief at 130% x 76,000 = £ 98,800 Question 6 Capital allowances are split into 3 pools: TWDV b/fwd Add water heating system Add packaging machinery Less short life assets General pool 30,000 Special pool Short life 5000 30,000 10,000 (4000) At 18% At 8% TWDV at close 40,000 7,200 30,000 2,400 2,400 7,200 1,000 180 180 Question 7 Interest charges are governed under the loan relationship rules. The interest on the bank overdraft can be set against net trade profit before qualifying charitable donations as it is an expense of the trade. Interest on the mortgage for the property is kept separate and added to the general non-trade loan relationship pool. Any non-trade loan relationship deficit is carried forward and can be set against non-trade loan relationship in future years. Question 8 Unilateral double tax relief applies to the property income. Relief is the lower of UK tax and foreign tax. Work out foreign tax: Foreign tax at 18% = 100/82 Total income of Betterdays: UK income Overseas income = 35,000 gross = tax (35,000 – 28,700) = 6,300 110,000 28,700 138,700 Small profits rate applies of 20% Tax on overseas income = 20% x 28,700 = 5,740 Therefore unilateral relief of 5,740 due Corporation tax liability = Total income Tax at 20% Less unilateral relief Corporation tax due 138,700 27,740 (5,740) 22,000 Question 9 The asset must be used in the company’s trade throughout the period of ownership. The new asset must also be an asset being acquired for the trade. The asset must be a qualifying asset – and land and buildings are qualifying assets. Helter must acquire the new asset between 12 months before or 3 months after the date of the sale of the old asset. If the whole of the proceeds are not invested in the new asset, the cash returned will be immediately chargeable gain subject to a maximum of the actual gain incurred on the original sale. Helter must acquire a qualifying asset and it does not need to fall into the same category as the asset that has been sold. Question 10 To be associated for CT purposes, Hold must control the other companies. Control means Hold owns more than 50% of the share capital. The dormant company is excluded. Therefore Hold is only associated with Cuddle and Hug. There are 3 associated companies. Companies associated means that any dividend income received from associated companies are disregarded when working out a company’s augmented profits. Furthermore, the augmented profit limits will be divided between the number of associated companies, in this case 3. Question 11 Tax adjusted trading profits Trading profits: Add disallowable expenditure Entertainment costs Cuban cigars disallowed Tax adjusted trading profit 805,000 1,300 700 807,000 Legal fees for updating employee contracts, and staff costs are deductible as they are costs incurred wholly and exclusively for the business. Question 12 Trading losses could be used against total taxable profits before qualifying charitable donations of Burn Ltd’s current year. Alternatively Burn Ltd could carry back the loss to the previous 12 months and set the loss against total taxable profits before qualifying charitable donations in the previous tax year. The final option is for Burns to carry forward the loss and utilize the loss against future trade profits. It would be more tax efficient for the loss to be utilized in current or previous year first and then carried forward the balance to future years.