(b) Draft a report as at today’s date advising Cutlass Inc on its proposed activities. The report should cover the

following issues:(i) The rate at which the profits of Cutlass Inc will be taxed. This section of the report should explain:

– the company’s residency position and what Ben and Amy would have to do in order for the company

to be regarded as resident in the UK under the double tax treaty;

– the meaning of the term ‘permanent establishment’ and the implications of Cutlass Inc having a

permanent establishment in Sharpenia;

– the rate at which the profits of Cutlass Inc will be taxed on the assumption that it is resident in the

UK under the double tax treaty and either does or does not have a permanent establishment in

Sharpenia. (9 marks)

[试题](b) For this part, assume today’s date is 1 May 2010.B．ill and Ben decided not to sell their company, and instead expanded the business themselves. Ben, however,is now pursuing other interests, and is no longer involved with the day to day activities

[试题](b) Draft a report suitable for inclusion in a Management Commentary for Jones and Cousin which deals with:(i) the key risks and relationships of the business (9 marks)

[试题]F．or this part, assume today’s date is 15 August 2005.5 (a) Donald is aged 22, single, and about to finish his university education. He has plans to start up a business sellingcomputer games, and intends to start trading on 1 April 2006, making up acc

[试题]4 (a) For this part, assume today’s date is 1 March 2006.B．ill and Ben each own 50% of the ordinary share capital in Flower Limited, an unquoted UK trading companythat makes electronic toys. Flower Limited was incorporated on 1 August 2005 with 1,000

[单选题]What's the date today?- _________。A.It's October.B.It's Monday.C.It's not t

[试题]4 Assume today’s date is 5 February 2006.Joanne is 37, she was born and until 2005 had lived all her life in Germany. She recently married Fraser, aged 38,who is a UK resident, but who worked briefly in Germany. They have no children.The couple moved

[试题]3 Assume that today’s date is 10 May 2005.You have recently been approached by Fred Flop. Fred is the managing director and 100% shareholder of FlopLimited, a UK trading company with one wholly owned subsidiary. Both companies have a 31 March year-end

[试题]2 Assume that today’s date is 1 July 2005.Jan is aged 45 and single. He is of Danish domicile but has been working in the United Kingdom since 1 May 2004and intends to remain in the UK for the medium to long term. Although Jan worked briefly in the UK

[试题]4 Assume today’s date is 15 May 2005.In March 1999, Bob was made redundant from his job as a furniture salesman. He decided to travel round the world,and did so, returning to the UK in May 2001. Bob then decided to set up his own business selling furn

[单选题]What's the date today?- _________A.October.B.MondayC.It's not the right tim