Transcript
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ACCA P6

Advanced Taxation

Question Based Revision -

Answers

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Question One

Letter

Audit and Tax Co

High Street

Chippenham

Mr H Gerald

4 – The Stables

Chippenham

1 April 2015

Dear Henry

Thank you for coming to see me last week. I set out below my findings following my review of the inheritance tax

calculations prepared by Vicky, my comments on your plans and some further advice to help you reduce your tax

liability.

(i) Inheritance tax

In respect of the gift on 1 July 2008, the nil band available will not be reduced by the value of the gift on 1

November 2005 as the latter gift was a potentially exempt transfer that took place more than seven years

prior to death.

In respect of the death estate, the Sevilan inheritance tax should be deducted from the UK inheritance tax

due and not from the value of the investment properties.

I am pleased to tell you that the correction of these errors results in a reduction in the inheritance tax due

of £111,520 as set out in the appendix to this letter.

(ii) Investments and pensions

Small Enterprise Investment Scheme

Your options to consider are, investing in venture capital trusts (VCTs), the Enterprise Investment Scheme

(EIS) and the SEED Enterprise Investment Scheme (SEIS). VCTs are quoted investment companies, which

hold investments in unquoted trading companies, thus spreading the risk over a portfolio of companies.

Your income tax liability would be reduced by 30% of the amount you invest in a VCT in any tax year up to

a maximum of 30% of £200,000. This relief would be withdrawn if you were to sell the shares within five

years.

There is no tax on the dividends received from a VCT and no taxable gains or allowable losses arise on the

sale of VCT shares.

With EIS you buy shares in an individual unquoted trading company, and therefore the investment is

perceived as higher risk.

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Your income tax liability would be reduced by 30% of the amount you invest in a EIS in any tax year up to

a maximum of 30% of £1,000,000. This relief would be withdrawn if you were to sell the shares within

three years.

With SEIS you buy shares in an individual small start-up unquoted trading company, and therefore this is

also perceived as higher risk.

Your income tax liability would be reduced by 50% of the amount you invest in a SEIS in any tax year up to

a maximum of 50% of £100,000. This relief would be withdrawn if you were to sell the shares within three

years.

Investing in SEIS does carry more perceived risk, so the best investment is dependant of your risk

appetite.

Pension contributions

You and Violet can each make tax allowable pension contributions up to the higher of £3,600 and your

relevant earnings. Relevant earnings consist of employment income, trading income and income from

furnished holiday accommodation. Furnished holiday accommodation is property situated in the UK or

EEA that satisfies the following conditions.

It is furnished and let on a commercial basis as holiday accommodation.

It is available for such lettings to members of the public for at least 210 days per year and is let for at

least 105 days per year.

Long-term occupation of the property (continuous occupation by the same person for more than 31

days) is limited to no more than 155 days per tax year.

At present, neither you nor Violet is in receipt of any relevant earnings. However, if you were to purchase

property in the UK, rather than in Sevila, and ensure that it satisfied the above conditions, you would be

able to make additional tax allowable pension contributions.

The annual allowance is £40,000, meaning you and Violet could make contributions of £40,000 each. The

tax saved would depend on your tax rate for the year.

(iii) Income tax planning

Ownership of quoted shares and government stocks

You are a higher rate taxpayer due to the level of your rental income, dividends and bank interest

£73,000 +£27,000 + (£21,000 x 100/90).

If the quoted shares and government stocks are owned personally by you, your annual tax liability on the

income received would be £20,050 as set out below. As your income would be more than £120,000, your

personal allowance would be fully withdrawn. This is only relevant to the tax cost decision if the

alternative suggestion does not result in a total withdrawal so is included for the present.

£

Tax on dividend income (£21,000 × 25%) 5,250

Government stocks (£27,000 × 40%) 10,800

Extra tax due to loss of PA (£10,000 × 40%) 4,000

––––––

Total tax suffered 20,050

––––––

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If the investments are transferred to a company, the company would pay corporation tax on the interest

income (but not on the dividends) at the rate of 21% regardless of the level of its profits. This is because it

is a company controlled by you that does not carry on a trading activity.

A calculation of the annual total tax payable using this structure is set out below.

Corporation tax Dividend

computation payable to you

£ £

Dividend income (exempt) – 21,000

Government stocks 27,000 27,000

––––––

Taxable total profits 27,000

––––––

Corporation tax at 21% 5,670 (5,670)

–––––– ––––––

Profits paid as dividend 42,330

––––––

Income tax liability (£42,330 × 25%) 10,582

Extra tax due to loss of PA (see below) (£10,000 × 40% ) 4,000

––––––

Total tax liability (£5,670 + £10,582 + £4,000) 20,252

––––––

There is an abatement to the personal allowance under this option either as gross personal income is

£73,000 + £42,330 x100/90 = £120,033. As your income would be more than £120,000, your personal

allowance would be fully withdrawn. It can be seen from the calculations above that it is more tax

efficient for the investments to be owned by you personally.

Transfer of assets to family members

You could reduce the tax due on your investments by making an absolute gift of some of them to Violet

(or your children). Violet will pay no income tax on her first £10,000 of income and will pay tax at a

maximum of 20% on the next £31,865 whereas you are paying income tax at up to 40%.The same savings

would be available if you were to transfer income generating assets to your adult children (on the

assumption that they have no other income).

Tax avoidance schemes

Tax avoidance involves arranging one’s affairs in such a way as to minimise one’s tax liabilities and is

perfectly legal. However, the promoter will provide details of the scheme to HM Revenue and Customs

and may be issued with a reference number. You will need to include this reference number in your

income tax return.

The rental income is taxable in the UK because you are a UK resident. Any tax suffered in Sevila can be

deducted from the UK liability but this cannot lead to a repayment of the Sevilan tax. Failure to disclose

the rental income arising on the Sevilan properties would amount to tax evasion, a criminal offence.

Please call me if you require any further explanations or advice. Yours sincerely

Tax manager

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APPENDIX:

Inheritance tax computation on death of father on 1 April 2015

Gifts of cash during father’s lifetime

£

1 July 2008 (£370,000 – £6,000 AEs) 364,000

Less: Nil band (325,000)

–––––

Taxable amount 39,000

–––––

Inheritance tax at 40% 15,600

–––––

Tapered (£15,600 x 20%) 3,120

–––––

Death estate

Per Vicky’s calculation 3,484,000

Add: Sevilan inheritance tax 160,000

–––––

Chargeable estate 3,644,000

–––––

Inheritance tax at 40% 1,457,600

Less: Relief for Sevilan tax

(less than UK tax at 40% on the Sevilan properties) (160,000)

–––––

1,297,600

––––––––

£

Total inheritance tax due (£3,120 + £1,297,600) 1,300,720

Per Vicky’s calculation 1,412,240

––––––––

Reduction in inheritance tax due 111,520

––––––––

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Question Two

(a) i Assessable income for Hans

Hans will be deemed UK resident as present for more than 183 days in the tax year 2014/15.

UK income will be taxed on the arising basis and overseas income will be taxed on either the arising or

remittance basis depending on the unremitted income.

If unremitted income is less than £2,000 it will be taxed under the remittance basis and the personal

allowance will be available. The Unremitted income is £1,700 so the above treatment is applicable.

(a) (ii) Income tax payable

Total OI SI DI £ £ £ £ Salary (Wk1) 90,570 90,570 Dividends £4,500 x 100/90 5,000 5,000 Interest from ISA - exempt Interest £760 X 100/80 950 950 Overseas income £4,900 X 100/45 10,889 10,889 Total income 107,409 101,459 950 5,000 Less Personal allowance (Wk2) (6,269) (6,269)

Taxable income 95,190 950 5,000 6,373 (31,865)

@.20

25,330 (63,325) @.40

380 950 @ .40 1625 5,000 @. 32.5 Income Tax liability 33,708 Less DTR Lower of UK @40% (10,889 X 40%) Overseas @55%

(4,356)

Dividend 5,000 x 10% (500) Interest (950 x 20%) (190) PAYE (25,000) Income tax payable 3,662

WK 1 Employment income

£ Salary £75,000 X 11/12 68,750 Car £40,550 X 35% x 9/12 95 12% 215 120/5 24% 36%

10,644

Fuel £21,700 X 35% X 9/12 5,696 Other benefits 5,480

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Employment income 90,570

WK 2 Revised personal allowance

£ Personal allowance 10,000 Abatement: (£107,409 - £100,000) X 50%

(3704)

Revised PA 6,269

(b) Accommodation

Basic charge

Higher of annual value £7,000 x 5/12 2,917

Rent paid by employer (5 x £660) 3,300

No expensive accommodation charge due to the company not owning the property.

(c) i) Paper for paper takeover

This is where there is an exchange of existing shares in a company for other shares of another company.

If the transaction is a share for share exchange the tax consequences are no capital gains tax charged at the time

of the takeover.

New shares are treated as if they were acquired at the same time and cost of the old shares.

Conditions for this to happened are:

The company issuing the new shares ends up with more than 25% of the ordinary share capital of the old

company or the majority of the voting power in the old company.

Or the company issuing the new shares makes a general offer to shareholders in the other company which is

initially made subject to a condition which, if satisfied, would give the first company control of the second

company.

The exchange must take place for bona fide commercial reasons, not to avoid capital gains tax.

(c) ii) Calculation

Cost £ Tongas 2,500 OS at £5.07 12,675

Bonus issue 2,500 x 9 22,500

Nil

Total shares 25,000 12,675

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Fijians

Cost £

MV at takeover

6 shares for every 10 25,000/10 x 6

11,420* 68,250

Cash 25,000 x 30p 1,255* 7,500 12,675 75,750 * 68,250/75,750 X 12,675 * 7,500/75,750 X 12,675

Tax implications:

Share for share No capital gains tax

Cash

Sale proceeds 7,500 Cost (1,255) Gain 6,245

Small part disposal is not applicable due to the cash being in excess of the £3,000 and 5% of the market value of

the shares.

(c) iii) Qualifying corporate bonds

Definition

It is a security that represents a normal commercial loan

Must be expressed in sterling

Person disposing of the bond must have acquired it after 13/3/84

Tax implications

A capital gain is calculated at the time of the takeover, as if the corporate bond were cashed.

The gain is not taxed at that time but frozen, and will only become chargeable on disposal.

The increase in value of the qualifying corporate bond from the date of take over to the date of sale is exempt

from capital gains tax.

Only the ‘frozen’ deferred gain becomes chargeable.

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Question Three

(a) Income tax payable

Total OI SI DI £ £ £ £ Pension 10,740 10,740 Interest 1,380 x 100/80 1,725 1,725 EASA (Gross) 390 390 Dividend 9,000 x 100/90 10,000 10,000 Dividend 27p x 30,000 = 8,100 x 100/90

9,000 9,000

Total income 31,855 10,740 2,115 19,000 Less Personal allowance (Wk1) (10,000) (10,000)

Taxable income 740 2,115 19,000 144 (740) @.20 2880-740 211 2,115@ .10 1,900 19,000 @.

10 Income Tax liability 2,255 Dividend 19,000 x 10% (1,900) Interest (1,725 x 20%) (345) PAYE (450) Income tax repayable (440)

WK 1 Revised personal allowance

£ Personal allowance 10,660 Abatement: (£31,855 - £27,000) X 50%

(2427)

Revised PA However everyone is entitled to the personal allowance of £10,000 apart from high earners

8,233 So use 10,000

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(a) IHT payable

Step 1 Lifetime transfers in life

PET CLT

Sept 09 March 11

09/10 10/11

Transfer of value 368,000 368,000

A/E 09/10 (3,000) 10/11 (3,000)

08/09 (3,000) 09/10 Used

Chargeable amount 362,000 365,000

No lifetime Tax

NRB at the date of gift 325,000

Less Gross chargeable transfers within 7 years of gift

-

(325,000)

Taxable amount 40,000

Donor pays the tax @ 25% 10,000

Gross chargeable transfer (£365,000 + £10,000) 375,000

Step 2 Lifetime transfers in death

15/02/15 – 15/02/08

PET CLT

Sept 09 March 11

09/10 10/11

Gross chargeable amount 362,000 375,000

NRB at the date of death 325,000 325,000

Less Gross chargeable transfers within 7 years of gift

- (362,000)

(325,000) -

Taxable amount 37,000 375,000

IHT @ 40% 14,800 150,000

Less Taper relief 9/09 – 02/15 5-6 years

60%

(8,880)

20% (30,000)

Lifetime tax paid - (10,000)

IHT payable 5,920 110,000

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Step 2 Lifetime transfers in death

Residence 455,000

Building society account 25,000

EASE 45,000

NS & I Saving certificates 190,000

Various Chattels 50,000

Share in Harvest Ltd

3,450 x 12 41,400

BPR 100% (41,400)

Shares in Banco Plc 30,000 x 6.27 wk1 188,100

Dividends 30,000 x 27p 8,100

Other 115,000

Income tax refund (a) 440

1,076,640

NRB at death 325,000

Less Gross chargeable transfers within 7 years of death (375,000 + 362,000)

(737,000)

NIL

Taxable estate 1,076,640

@40% 430,656

The estate is equally split between James and amber each receiving £343,692

(1,076,640+41,400–430,656)/2

WK 1 Share value on Banco PLc

Lower of

Quarter up rule 625 + ¼ (635-625) = 6.275

Bargin 625+635/2 =6.300

(c) i Trusts

James has a choice of setting up either an interest in possession trust or a discretionary trust.

Interest in possession trust

An interest in possession trust is where the beneficiaries will be legally entitled to the income generated by the

trust each year and it must be paid.

This wouldn’t suit James due to the fact he wants to keep control.

Discretionary trust

A discretionary trust is whereby the trustees have the discretion (choice) of how the funds will be used. If James

was a trustee then this would give him the control he wants.

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Inheritance tax implications

Gifts into relevant property are immediately chargeable to inheritance tax, and will attract inheritance tax if in

excess of any unused band.

If James dies within 7 years of the gift there may be a further charge incurred.

(c) ii Other advice

If James creates a discretionary trust this will be a chargeable lifetime transfer, and could give rise to a charge in

lifetime and on death, if the gift falls within 7 years from death.

James wouldn’t qualify for BPR as he hasn’t held the shares in Harvest Ltd for 2 years.

What would be advisable is to pass his inheritance directly to the children by using a deed of variation and alter

Joe’s estate.

There will be no change on inheritance tax on the estate, however for James there will be no chargeable lifetime

transfer and therefore preserve his nil rate band.

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Question Four

(a) Income tax liability – 2014/15 £ Pension 19,080 Building society interest (£4,180 × 100/80) 5,225 Dividends (£3,168 × 100/90) 3,520 –––––– Total income 27,825 Less: Personal allowance (W1) (10,088) –––––– Taxable income 17,737 –––––– Analysis of income: Savings £5,225; Dividends £3,520; Other income £8,992 Income tax £ 8,992 at 20% 1,798 5,225 at 20% 1,045 3,520 at 10% 352 –––––– 17,737 –––––– –––––– Income tax liability 3,195

Capital gains tax liability – 2014/15 £ £ Ordinary shares in Mega plc Market value (W2) (55,000 at 219.5p) 120,725 Less: Cost (W3) (46,933) 73,792 Main residence Deemed consideration 269,500 Less: Cost (161,260) ––––––– Capital gain 108,240 ––––––– Chargeable gain (W4) 8,277 –––––– Total chargeable gains 82,069 Less: Annual exempt amount (11,000) –––––– Taxable gains 71,069 ––––––

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Capital gains tax £ £ Basic rate (£31,865 – £17,737)

14,128 × 18% 2,543

Higher rate 56,941 × 28% 15,943 –––––– 71,069 –––––– –––––– Capital gains tax liability 18,486 ––––––

W1) Personal allowance: born between 6.4.1938 and 5.4.1948 Laura’s total income exceeds the income limit by £825 (£27,825 – £27,000), so Laura’s personal allowance of £10,500 is reduced by half of the excess to £10,088 (£10,500 – ½ × £825). (W2) Market value Mega plc Shares Lower of: (i) ¼ up valuation (218 + ¼ × (224 – 218)

219.5

(ii) Mid bargain (217 + 224) × ½ 220.5

(W3) Cost of Mega plc Shares Number Cost £ £ 16 Dec 2013 44,000 25,960 16 Jan 2014 RI (1:2) @ £1.38 22,000 30,360 –––––– –––––– 66,000 56,320 9 July 2014 Disposal (55,000) £56,320 × (£55,000/£66,000) (46,933) –––––– –––––– Balance c/f 11,000 9,387 –––––– ––––––

W4) Chargeable gain on main residence The main residence was owned for 17 years. For 6½ years, 20% was used for business purposes. Therefore 20% of 6½/17 (= 78/204ths) of the gain is chargeable. The remaining gain is exempt under the PPR rules.

Chargeable gain = (£108,240 × 78/204 × 20%) = £8,277

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(b) IHT implications of gifts Ordinary shares in Mega plc Laura’s gift of shares in Mega plc on 9 July 2014 will be a PET of £114,725. This is calculated as £120,725 per the CGT valuation less two annual exemptions of £3,000 for 2014/15 and 2013/14. As a PET, no IHT is payable at the date of the transfer. Assuming Laura dies on 31 January 2019 (i.e. within 7 years of the gift), the PET will become chargeable. However, it will be covered by the nil rate band of £325,000 and therefore no tax is payable. Gift to the discretionary trust The cash gift of £340,000 into the discretionary trust on 25 September 2014 will be a chargeable lifetime transfer. No annual exemptions are available as they have been used against the gift on 9 July 2014. There are no chargeable transfers in the previous seven years (PETs are ignored in lifetime calculations). IHT payable is therefore: (£340,000 – £325,000) × 25% = £3,750 IHT of £3,750 is due by 30 April 2015. The gross gift to carry forward is £343,750 (£340,000 + £3,750). Death tax

As a result of Laura’s death on 31 January 2019, additional IHT will be due. The PET made on 9 July 2014 becomes

chargeable, and this will utilise £114,725 of the nil rate band. The nil rate band available is £210,275 (£325,000 –

£114,725).

Gross chargeable transfer 343,750 ––––––– IHT liability (£343,750 – £210,275) × 40% 53,390 Less: Taper relief (4 – 5 years) (£53,390 × 40%) (21,356) ––––––– 32,034 Less: IHT paid on lifetime gift (3,750) ––––––– IHT due on death 28,284 –––––––

Gift of the main residence Laura’s gift of her main residence on 28 February 2015 will not be treated as a gift with reservation and will not be caught by the pre-owned asset rules.

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Although she has continued to live in the house, she is paying a full market rent for doing so. The gift will

therefore be a PET of £269,500. No annual exemptions are available as they have been used against the gift on 9

July 2014.

The PET becomes chargeable on death as follows: £ Gross chargeable transfer 269,500 ––––––– No nil rate band available. IHT liability (£269,500 × 40%) 107,800 Less: Taper relief (3 – 4 years) (£107,800 × 20%) (21,560) ––––––– IHT due on death 86,240 –––––––

Gift with reservation If Laura did not pay a full market rent for continuing to live in her main residence, the gift on 28 February 2015 would be a gift with reservation. Instead of treating the gift as a PET, the house would be included in Laura’s estate at its value on 31 January 2019.

It is therefore beneficial that Laura is paying a full market rent, as property values are expected to increase and

therefore inclusion in the estate at a higher value and the loss of taper relief will result in a higher IHT charge.

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Question Five

a) Principal private residence relief The disposal of a property that has been occupied as a main residence throughout the period of ownership is exempt from CGT under the principal private residence provisions. If the property has not been used as a main residence throughout the period of ownership a capital gain is calculated in the ‘normal way’. Any exempt portion is then calculated using the formula below: Exempt gain = Total gain × (Period of occupation/Total period of ownership) It is important to note, however, that in certain circumstances some periods of actual absence from the property are counted as periods of occupation. These circumstances are as follows: (a) Providing there has been a period of actual occupation as a main residence, the last 18 months of ownership is always exempt. (b) Providing there has been both a period of occupation as a main residence before and after the absence period: (i) Any absence period when the individual was employed overseas.

(ii) Any absence period (or periods) that together do not exceed four years, throughout which the individual was working elsewhere in the UK in circumstances where the location of the employment was too far from the property to live in it.

(iii) Any absence period (or periods) for any reason that together do not exceed three years.

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b) Sale of principal private residence (i) If Rosalind returns to occupy the house in Wales as her main residence prior to sale the CGT implications will be as follows: 2014/15 – Gain on the sale of house with reoccupation Original house Extension £ £ Gross sale proceeds 80,000 20,000 Less: Disposal costs (80:20) (3,200) (800) ––––––– ––––––– Net sale proceeds 76,800 19,200 Less: Cost (W1) (122,000) (15,000) ––––––– ––––––– (Loss)/Gain before reliefs (45,200) 4,200 Less: PPR exemption (W2) 45,200 – ––––––– ––––––– Chargeable gain Nil 4,200 Less: Annual exempt amount – (11,000) ––––––– ––––––– Taxable gain Nil Nil ––––––– ––––––– 2015/16 – Sale of shares

Following the sale of her shares, after taking into account her annual exempt amount of £11,000, Rosalind will

have a CGT liability of £3,332 ((£22,900 – £11,000) × 28%) for this tax year.

If Rosalind sells the house in Wales without returning to occupy as main residence the CGT implications will be as follows: 2014/15 – Gain on the sale of house without reoccupation As Rosalind will no longer return to occupy the house in Wales, the 39 month period 1 July 2010 to 30 September 2013 will no longer be exempt. As a consequence, the capital gains calculation is now as follows: Original house non-business asset

Extension business asset

£ £ (Loss)/gain before reliefs – as before

(45,200) 4,200

Less: PPR exemption (W2) 34,516 – ––––––– ––––––– (Loss)/gain after PPR (10,684) 4,200 Less: Loss offset in 2014/15 4,200 (4,200) ––––––– Allowable loss carried forward (6,484) ––––––– ––––––– Chargeable gain Nil –––––––

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2015/16 – Sale of shares Following the sale of her shares, after taking into account her annual exempt amount of £11,000 and the capital loss of £6,484 brought forward from 2013/14, Rosalind will have a CGT liability of only £1,516 ((£22,900 – £11,000 – £6,484) × 28%). This will give an overall CGT saving under this alternative of £1,816 (£3,332 – £1,516). Conclusion

It would therefore appear advisable for Rosalind not to return to live in her house in Wales prior to its sale.

Workings (W1) Cost of house The disposal of part of the property in June 2004 is a part disposal for CGT purposes. As a result, the A/(A + B) formula needs to be used to establish the remaining base cost for future disposal purposes. This is calculated as follows:

£

Original cost 180,000 Incidental acquisition costs 3,000 ––––––– 183,000 Allocated to earlier disposal £70,000 / (£70,000 + £140,000) × £183,000 (61,000) ––––––– Residual base cost 122,000 –––––––

(W2) Principal private residence exemption If Rosalind returns to occupy the Welsh house as her main residence, as demonstrated below, her entire period of ownership will be exempt for CGT purposes. Total (months)

Exempt (months) Chargeable (months)

1.7.2001 to 30.6.2004 36 36 (actual occupation) 1.7.2004 to 31.3.2008 45 45 (absence for UK work) 1.4.2008 to 30.6.2010 27 27 (actual occupation) 1.7.2010 to 30.9.2013 39 39 (absence for UK work – remaining 3 months plus any other reason 36 months) 1.10.2013 to 31.3.2015 18 18 (last 18 months of ownership) –––– –––– –––– 165 165 Nil –––– –––– ––––

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If Rosalind does not reoccupy the house: The period 1 July 2010 to 30 September 2013 is no longer exempt. Therefore the chargeable portion is: 39/165 The PPR exempt portion is: 126/165

PPR = (126/165 × £45,200) = £34,516

(c) Income tax implications of renting a house Assuming that Rosalind decides to remain in Manchester the principal tax implications involved in renting out her house in Wales are as follows: She will be assessed on property business income, at her marginal tax rates (presumably 40%), on any net profit arising from the letting of this property. This will need to be declared as part of her self-assessment tax return. The assessable net profit is found by deducting from any rents receivable for any particular tax year the allowable expenditure calculated on the accruals basis. Allowable expenditure includes property insurance, letting agents fees, repairs (but not capital expenditure) and loan interest. If the property is let on a furnished basis an additional deduction, the wear and tear allowance, can be claimed. This is calculated as 10% of any assessable rents (less any council tax and water rates paid).

Capital allowances can only be claimed on plant and machinery used in managing the property (e.g. lawnmower).

If a loss arises, such losses can only be carried forward for offset against any future rental profits made.

If the letting satisfies certain conditions the property will be classified as furnished holiday accommodation (FHA). The qualifying conditions are:

the property is available for commercial letting, to the public, for not less than 210 days per tax year; and it is actually let for at least 105 days in a tax year; and the property must not be let for periods of long term occupation totalling in excess of 155 days in the

relevant 12 month period. Long term occupation is a period of more than 31 consecutive days let to the same person.

The benefits of being classed as FHA are: (i) Profits count as earnings for personal pension purposes.

(ii) ‘Normal’ capital allowances will be available for any furniture purchased.


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