TAXATION OF MAJOR CORPORATES TECHNICAL KNOWLEDGE

Transcription

1 TAXATION OF MAJOR CORPORATES TECHNICAL KNOWLEDGE

2 Capital Gains Tax Taxation of Major Corporates Capital Gains Tax and Corporation Tax on Capital Gains The charge to tax and persons chargeable (s. to s.8 TCGA 992) Residence Computation of Gains and Acquisitions and Disposals of Assets Computation of gains and losses Use of losses Transactions treated as made at market value Transactions between connected parties Disposal in a series of transactions Assets and disposals of assets (s.2 to s.28 TCGA 992) Value shifting (s.3 to s.34 TCGA 992) Rebasing to 982 Allowable deductions Wasting assets 2 Miscellaneous computational provisions (s.48 to s.52 TCGA 992) 2 Indexation allowance Shares, Securities, Options etc Gilt edged securities and qualifying corporate bonds Capital distribution in respect of shares Reorganisation or reduction of share capital Conversion of securities Company reconstructions Transfers concerning companies of different member states 2 Formation of SE by merger (s.40h to s.40l TCGA 992) 2 Stock dividends Miscellaneous (s.5ba to s.5g TCGA 992) 2 Excluded: Sections 8-20, 24, 50, 5C, 5D TCGA 992 2

3 Transfer of Business Assets Replacement of business assets Stock in trade Companies Groups and transactions within groups Losses attributable to depreciatory transactions Anti-gain buying Companies leaving groups Non-resident and dual resident companies Recovery of tax otherwise than from taxpayer company Substantial shareholding exemption Excluded: Sections TCGA 992 Other Property, Businesses, Investments etc Share schemes Leases of land and other assets Part disposals Debts Know how 2 Deduction of trading losses or post-cessation expenditure, etc 2 Repurchase price under repos 2 Excluded: Sections , 237, 239A, 249, 250, 263AZA-27 TCGA 992 Supplemental Supplemental matters contained in s.272 to s.29 TCGA 992 Post transaction valuations Marren v Ingles Corporation Tax Accounting Standards Accounting standards in so far as they may impact tax and the tax consequences of alternative accounting treatments Administration and Computation of Liability Corporation tax self-assessment system 3

4 Calculation of liability in respect of profits Companies with small profits Loss relief Group relief Charitable donations relief Leasing plant and machinery - long funding leases only Companies in liquidation or administration Change in company ownership Transactions in securities Factoring in income - transfers of income streams 2 Transactions in land Sale and leaseback 2 Miscellaneous provisions - part 22 CTA 200 Company distributions excluding demergers and purchase of own shares Computation of Taxable Profits The charge to corporation tax and accounting periods Company residence and chargeable profits of non-uk resident companies and concept of permanent establishment/branch Trading income excluding Herd Basis and Other Specific Trades Property income Loan relationships Relationships treated as loan relationships Derivative contracts - basic principles 2 Intangible fixed assets and intellectual property 2 Company distributions received Income not otherwise charged - chapter 8, part 0 CTA 2009 Relief for employee share acquisition schemes Additional relief for expenditure on research and development - Large companies only Companies with investment businesses Unremittable income General exemptions - part 9 CTA

5 General calculation rules - part 20 CTA 2009 Miscellaneous Matters and Anti-avoidance Migration of company 2 Controlled foreign companies 2 Double tax treaties - OECD model Double tax relief Transfer pricing and advance pricing agreements Patent Box Regime - basic principles 2 Tax treatment of financing costs and income Deduction of income tax Disclosure of avoidance schemes Role and responsibilities of the Senior Accounting Officer Impact of EU law and cases in so far as they impact UK taxation Stamp taxes and groups of companies Capital allowances - post April 200 rules only will be examined Part CAA 200 Plant and machinery allowances Introduction (s. to s.4 CAA 200) Qualifying activities Qualifying expenditure First year qualifying expenditure Annual Investment Allowance Other allowances and charges Hire purchase, etc and plant provided by lessee Long funding leases Computer software Cars, etc Short life assets Long life assets Special rate expenditure 5

6 Fixtures Assets provided or used only partly for qualifying activities Avoidance involving allowance buying and other anti-avoidance 2 Additional VAT liabilities and rebates (s.234 to s.240 CAA 200) 2 Giving effect to allowances and charges Use of plant or machinery for business entertainment Excluded: Sections 34-38, 40-43, 27-7, , , 270 Research and development allowances Know how allowances 2 Patent allowances 2 Contributions Supplementary provisions Successions Transfers - s.56, 56A CAA 200 Miscellaneous - s a CAA 200 Final provisions - s CAA 200 Excluded: Parts 3, 3A, 4, 4A, 5, 9, 0; Sections , , 560 CAA 200 Notes a) = core material, 2 = non-core material. b) In addition to the detailed syllabus above, the syllabus includes the VAT Awareness Module Syllabus plus material from the ACA Certificate Level Principles of Taxation and the ACA Professional Level Tax Compliance modules in so far as it is relevant to a major corporate. c) The split of the paper will be: 80% to 00% from the detailed Taxation of Major Corporates syllabus above 0% to 0% from the VAT Awareness Module syllabus 0% to 0% from the ICAEW papers d) Of the material from the detailed Taxation of Major Corporates syllabus, 75% or more will be core material. 6