[ashton1983]

Who remembers clearly the question breakdown for question 3 ?

I’m only remembering

Related property husband + wife shares . Gifting in 2013 or 2016 to daughter

Then the other one regarding change in cessation date 28/02 or 30/04

Was there another part of the question ?

[ashton1983]

IR35 rules , Helena i did the same.
BPR i could not rem rules but i assumed and APR relief , i figured that out – 10 years (Tenant min 7 years).
Qsr i didnt study that.

Domicile status – deemed domicile 17/20 years rule. she had 26 years.
Inheritance tax payable.

cash gift. individual to individual lifetime gift, PET.
in 2016 , it would have passed the window period.

[ashton1983]

i agree branches treatment was quite straighforward and easy.
irevocable exemption – lose out on future losses. group relief
DTR implications lower of UK or overseas tax

Companies , well not clear had to make ASSUMPTIONS since they stated that subsidiaries would be wholly owned, that may raise the implication of CFC rules and risks, so i hammered towards that route. the alternative , FII exempt dividend should there not been control.

VAT implications
the marks were just too much.So i took it from the point that both companies were VAT registered and assumed that it was not a VAT group , so basing on that assumption ,i went the TOGC route.

Imports.
outside EU/ if been a local supplier chargeable at standard rate
VAT output accounted on point of entry
VAT input recovery on next VAT return.
Bonded warehouse implications.

exam was not easy

[Author]

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