3 Palm plc recently acquired 100% of the ordinary share capital of Nikau Ltd from Facet Ltd. Palm plc intends to use

Nikau Ltd to develop a new product range, under the name ‘Project Sabal’. Nikau Ltd owns shares in a non-UK

resident company, Date Inc.

The following information has been extracted from client files and from a meeting with the Finance Director of Palm

plc.

Palm plc:

– Has more than 40 wholly owned subsidiaries such that all group companies pay corporation tax at 30%.

– All group companies prepare accounts to 31 March.

– Acquired Nikau Ltd on 1 November 2007 from Facet Ltd, an unrelated company.

Nikau Ltd:

– UK resident company that manufactures domestic electronic appliances for sale in the European Union (EU).

– Large enterprise for the purposes of the enhanced relief available for research and development expenditure.

– Trading losses brought forward as at 1 April 2007 of ￡195,700.

– Budgeted taxable trading profit of ￡360,000 for the year ending 31 March 2008 before taking account of ‘Project

Sabal’.

– Dividend income of ￡38,200 will be received in the year ending 31 March 2008 in respect of the shares in Date

Inc.

‘Project Sabal’:

– Development of a range of electronic appliances, for sale in North America.

– Project Sabal will represent a significant advance in the technology of domestic appliances.

– Nikau Ltd will spend ￡70,000 on staffing costs and consumables researching and developing the necessary

technology between now and 31 March 2008. Further costs will be incurred in the following year.

– Sales to North America will commence in 2009 and are expected to generate significant profits from that year.

Shares in Date Inc:

– Nikau Ltd owns 35% of the ordinary share capital of Date Inc.

– The shares were purchased from Facet Ltd on 1 June 2003 for their market value of ￡338,000.

– The sale was a no gain, no loss transfer for the purposes of corporation tax.

– Facet Ltd purchased the shares in Date Inc on 1 March 1994 for ￡137,000.

Date Inc:

– A controlled foreign company resident in the country of Palladia.

– Annual chargeable profits arising out of property investment activities are approximately ￡120,000, of which

approximately ￡115,000 is distributed to its shareholders each year.

The tax system in Palladia:

– No taxes on income or capital profits.

– 4% withholding tax on dividends paid to shareholders resident outside Palladia.

Required:

(a) Prepare detailed explanatory notes, including relevant supporting calculations, on the effect of the following

issues on the amount of corporation tax payable by Nikau Ltd for the year ending 31 March 2008.

(i) The costs of developing ‘Project Sabal’ and the significant commercial changes to the company’s

activities arising out of its implementation. (8 marks)

(ii) The shares held in Date Inc and the dividend income received from that company. (7 marks)

(b) Advise Sergio on the appropriateness of investing in a domestic rental property in view of his personal

circumstances and recommend suitable alternative investments giving reasons for your advice. (4 marks)

(d) Evaluate the effect on Gerard of the changes to be made by Fizz plc to its performance related bonus scheme.

You should ignore the effect of any pension contributions to be made by Gerard in the future, consider both

the value and timing of amounts received by Gerard and include relevant supporting calculations.

(5 marks)

Note: – You should assume that the income tax rates and allowances for the tax year 2006/07 apply throughout

this question.

(b) Explain why making sales of Sabals in North America will have no effect on Nikau Ltd’s ability to recover its

input tax. (3 marks)

Notes: – you should assume that the corporation tax rates and allowances for the financial year to 31 March 2007

will continue to apply for the foreseeable future.

– you should ignore indexation allowance.

(ii) A proposal which will increase the after tax proceeds from the sale of the Snapper plc loan stock and a

reasoned recommendation of a more appropriate form. of external finance. (3 marks)

(b) (i) Explain, by reference to Coral’s residence, ordinary residence and domicile position, how the rental

income arising in respect of the property in the country of Kalania will be taxed in the UK in the tax year

2007/08. State the strategy that Coral should adopt in order to minimise the total income tax suffered

on the rental income. (7 marks)

(b) Explanations of the various matters. (11 marks)

(ii) Explain how the inclusion of rental income in Coral’s UK income tax computation could affect the

income tax due on her dividend income. (2 marks)

You are not required to prepare calculations for part (b) of this question.

Note: you should assume that the tax rates and allowances for the tax year 2006/07 and for the financial year to

31 March 2007 will continue to apply for the foreseeable future.

4 (a) A company may choose to finance its activities mainly by equity capital, with low borrowings (low gearing) or by

relying on high borrowings with relatively low equity capital (high gearing).

Required:

Explain why a highly geared company is generally more risky from an investor’s point of view than a company

with low gearing. (3 marks)