更多服务

特色服务

找学习资源

查报考信息

看备考资讯

备考工具箱

报考指南

报考条件

就业前景

报考流程

考试日历

资料中心

注册流程

准考证

免费题库

全部

ACCA考试复习回顾《税务F6》辅导6

来源：高顿网校 2015-03-23

　　OVERSEAS ASPECTS OF CORPORATION TAX

　　RELATED LINKS

　　This article is relevant to candidates sitting Paper F6 （UK） in either June or December 2013, and is based on tax legislation as it applies to the tax year 2012–13 （Finance Act 2012）。

　　Overseas aspects of corporation tax may be examined as part of Question 2, or it could be examined in Questions 4 or 5.

　　Company residence Companies that are incorporated in the UK are resident in the UK. Companies that are incorporated overseas are only treated as being resident in the UK if their central management and control is exercised in the UK. Companies that are resident in the UK （or treated as being resident in the UK） are subject to UK corporation tax on their worldwide profits （including chargeable gains）。

　　Example 1 Crash-Bash Ltd is incorporated overseas, although its directors are based in the UK and hold their board meetings in the UK.

　　· Companies that are incorporated overseas are only treated as being resident in the UK if their central management and control is exercised in the UK.

　　· Since the directors are UK based and hold their board meetings in the UK, this would indicate that Crash-Bash Ltd is managed and controlled from the UK, and therefore it is resident in the UK.

　　· If the directors were to be based overseas and to hold their board meetings overseas, the company would probably be treated as resident overseas since the central management and control would then be exercised outside the UK.

　　Overseas dividends As far as Paper F6 （UK） is concerned all overseas dividends are exempt from UK corporation tax.

　　Exempt overseas dividends are included as franked investment income when calculating a company’s augmented profits in exactly the same way as UK dividends, unless they are group income. In this case they are completely ignored for tax purposes.

　　Example 2 During the year ended 31 March 2013 Various Ltd, a UK resident company, received an overseas dividend of ?67,500 （net）。 Withholding tax was withheld from the dividend at the rate of 15%.

　　· If Various Ltd owns 50% or less of the voting power of the overseas company, then the overseas dividend will be exempt from UK corporation tax but included as

　　franked investment income. The amount of franked investment income is ?75,000

　　（67,500 x 100/90）。

　　· If Various Ltd owns more than 50% of the voting power of the overseas company,

　　then the dividend will be exempt from UK corporation tax and not included as

　　franked investment income. This is because the overseas dividend is group

　　income.

　　Overseas branches

　　An overseas branch of a UK company is effectively an extension of the UK trade, and

　　100% of the branch profits are assessed to UK corporation tax. Double taxation relief

　　is then given where an overseas branch’s profits are also taxed overseas. Relief is

　　restricted to the amount of UK tax on the overseas branch’s profits. If an overseas

　　branch makes a trading loss then the loss can be relieved against UK profits.

　　Example 3

　　Gong Ltd is a UK resident company with an overseas branch. For the year ended 31

　　March 2013 the company made a trading profit of ?370,000, and the branch made a

　　trading profit of ?30,000. Overseas corporation tax of ?6,300 was paid in respect of

　　the overseas branch’s trading profit.

　　Gong Ltd’s corporation tax liability for the year ended 31 March 2013 is as follows:

　　UK trading profit 370,000

　　Overseas branch 30,000

　　_______

　　Taxable total profits 400,000

　　_______

　　Corporation tax at 24% 96,000

　　Marginal relief 1/100 （1,500,000 – 400,000）（11,000）

　　_______

　　85,000

　　Double taxation relief （6,300）

　　_______ 78,700

　　_______ The overseas branch has paid overseas corporation tax of ?6,300, and this is lower than the related UK corporation tax of ?6,375 （85,000 x 30,000/400,000）。

　　As an alternative to this treatment it is possible for a company to elect to simply treat the profits of all of its overseas branches as being exempt from UK corporation tax. The election, once made, is irrevocable, and it applies to all of a company’s overseas branches. The election must be made before the start of an accounting period to which it is to apply.

　　An election will not be beneficial if a company has a loss making overseas branch, since if an election is made any trading loss of an overseas branch will not be relievable when calculating taxable total profits. Even if a branch is currently profitable, a company might decide not to make an election if double taxation relief means there is little or no UK corporation tax liability in respect of the branch profits. This will mean that relief will then be available should the branch make a loss at some point in the future.

　　Example 4 Brown Ltd is a UK resident company with two overseas branches. For the year ended 31 March 2013 the company made a trading profit of ?210,000. The first overseas branch made a trading profit of ?40,000 for the year ended 31 March 2013. Overseas corporation tax of ?6,000 was paid in respect of this profit. The second overseas branch made a trading loss of ?25,000 for the year ended 31 March 2013. Brown Ltd has not made an election to exempt the profits of its overseas branches.

　　Brown Ltd’s corporation tax liability for the year ended 31 March 2013 is as follows:

　　? UK trading profit 210,000

　　First overseas branch

　　40,000 Second overseas branch （25,000）

　　_______

　　? Taxable total profits 225,000

　　_______

　　Corporation tax at 20%

　　45,000 Double taxation relief （6,000）

　　_______ 39,000

　　_______

　　· The first overseas branch has paid overseas corporation tax of ?6,000, and this is lower than the related UK corporation tax of ?8,000 （40,000 at 20%）。

　　If Brown Ltd had made an election to exempt the profits of its overseas branches prior to 1 April 2012, then its corporation tax liability would have been as follows:

　　? UK trading profit 210,000

　　_______ Taxable total profits 210,000

　　_______

　　Corporation tax at 20%

　　42,000 _______

　　Therefore an election would not have been beneficial.

　　Overseas branch compared to an overseas subsidiary company It is important to appreciate the difference between operating overseas through a branch and operating overseas through a subsidiary company. An overseas branch of a UK company is effectively an extension of the UK trade, and （if no election for exemption is made） 100% of the branch profits are assessed to UK corporation tax. There are a number of factors that have to be considered when deciding whether to operate overseas through either a branch or a subsidiary company.

　　Example 5 Union Ltd is a UK resident company that is planning to set up an overseas operation. It is unsure whether to operate overseas through a branch or a 100% subsidiary company.

　　If no election for exemption is made

　　· Relief will usually be available for trading losses if incurred by an overseas branch. As far as Paper F6（UK） is concerned, no UK relief is available for trading losses incurred by an overseas subsidiary company.

　　· UK capital allowances will be available in respect of plant and machinery purchased by an overseas branch. Allowances will not be available for expenditure incurred by an overseas subsidiary company.

　　· The profits of an overseas branch are liable to UK corporation tax in the year that they are made, regardless of whether they are remitted to the UK. An overseas subsidiary company will not be liable to UK corporation tax.

　　· An overseas branch cannot be an associated company. An overseas subsidiary will be an associated company, and so the UK corporation tax limits will be reduced accordingly.

　　If an election for exemption is made

　　· As far as the calculation of taxable total profits is concerned, there will be no difference whether Union Ltd operates through an overseas branch or an overseas subsidiary company.

　　· However, the UK corporation tax liability could be higher as a result of operating through an overseas subsidiary company since this will be an associated company.

　　Transfer pricing The transfer pricing rules prevent UK companies from reducing their taxable total profits subject to UK corporation tax by, for example, making sales at below market price to an overseas subsidiary company, or purchasing goods at above market price from an overseas holding company.

　　Example 6 Frodo Ltd, a UK resident company, exports goods that it has manufactured to its overseas subsidiary company at less than their market price.

　　· Invoicing for the exported goods at less than the market price will reduce Frodo Ltd’s UK trading profit and hence UK corporation tax.

　　· A true market price must therefore be substituted for the transfer price.

　　· The market price will be an ‘arms length’ one that would be charged if the parties to the transaction were independent of each other.

　　· Frodo Ltd will be required to make the adjustment in its corporation tax self-assessment tax return.

　　Conclusion The overseas aspects of corporation tax, at Paper F6 （UK） level, are fairly straightforward provided you know the main principles involved. Working through the examples in this article should prepare you for anything that might be set in the examination.

　　Written by a member of the Paper F6 examining team

　　通过ACCA考试实属不易，首先要有执着的精神，其次是不断勤奋的学习，高顿网校为大家提供ACCA题库免费做题，希望助大家一臂之力，查看详情》

ACCA网络课程	课程专业名称	讲师	试听
85%的人正在学习该课程	ACCA 全维度网课体验课程实景课堂与独立录制覆盖所有知识点，根据学习计划推进学习进度	高顿名师
70%的人正在学习该课程	ACCA网课全科卡（8.2折）为零基础刚开始学习ACCA的学员特别定制	高顿名师

　　ACCA考试免费题库【手机题库下载】| 在线直播

　　ACCA高清网课免费体验 ACCA名师精品班免费试听

　　精彩推荐：

ACCA到底是什么意思？

ACCA特许公认会计师职业发展与分析

2015年6月ACCA考试常见问题解析

2015年6月ACCA备考辅导专题　　2014年ACCA考试真题和答案汇总

版权声明：本条内容自发布之日起，有效期为一个月。凡本网站注明“来源高顿教育”或“来源高顿网校”或“来源高顿”的所有作品，均为本网站合法拥有版权的作品，未经本网站授权，任何媒体、网站、个人不得转载、链接、转帖或以其他方式使用。经本网站合法授权的，应在授权范围内使用，且使用时必须注明“来源高顿教育”或“来源高顿网校”或“来源高顿”，并不得对作品中出现的“高顿”字样进行删减、替换等。违反上述声明者，本网站将依法追究其法律责任。本网站的部分资料转载自互联网，均尽力标明作者和出处。本网站转载的目的在于传递更多信息，并不意味着赞同其观点或证实其描述，本网站不对其真实性负责。如您认为本网站刊载作品涉及版权等问题，请与本网站联系(邮箱fawu@gaodun.com，电话：021-31587497)，本网站核实确认后会尽快予以处理。

展开全文咨询在线

点一下领资料

【整理版】ACCA各科目历年真题

真题高频考点，刷题全靠这份资料

下载合集

acca全科学习思维导图

梳理核心考点，一图看懂全部章节

下载合集

2023年acca考纲解析

覆盖科目重难点,备考按照计划走

acca备考热门问题解答

acca考试怎么搭配科目？: 建议优先选择相关联的科目进行搭配报考，这样可以提高备考效率，减轻备考压力，1、F1-F4：为随时机考科目，难度较低，这里可以自行随意选择考试顺序。2、F5-F9：如果你的工作的和财务会计或者审计有关、或者你比较擅长财务和审计的话，推荐先考F7和F8。你可以选择一起考ACCA考试科目F7和F8或者先考F7（8）再考F8（7），这就要取决你一次想考几门。3、P阶段：选修科目中，建议企业首选AFM！第二部分科目进行选择，如果AA和SBR掌握学生更好，可以通过选择AAA，如果SBL掌握的好，可以自己选择APM。