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Question 5c ii

Klubb plc:
– Is a UK resident trading company.
– Has been charged a penalty in respect of the late filing of corporation tax returns.
– Intends to establish an approved tax-efficient share plan.
– Purchased 30% of the ordinary share capital of Hartz Co from Mr Deck on 1 April 2014.

Hartz Co:
– Is resident in the country of Suta.
– Mr Deck continues to own 25% of the company’s ordinary share capital.
– Kort Co, a company resident in the country of Suta, owns the remaining 45%.

Budgeted results of Hartz Co for the year ending 31 March 2015:
– Trading profits of £330,000.
– Chargeable gains of £70,000.
– All of Hartz Co’s profits have been artificially diverted from the UK.
– Hartz Co will pay corporation tax at the rate of 11% in the country of Suta.
– Hartz Co will not pay a dividend for the year ending 31 March 2015.

Required:
(c) (ii) On the assumption that Hartz Co is a CFC, and that no CFC exemptions are available, calculate the budgeted CFC charge for Klubb plc based on the budgeted results of Hartz Co for the year ending 31 March 2015. (3 marks)

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