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6 * Business property relief. * Use of second spouse nil rate band. * Related property.

* Groups of companies, trading and capital losses. * Double tax relief for companies. * De-grouping charges. * ncorporation relief. * !urnished holiday lets. * "#$ partial exemption. * #ppeals and the four trac% tribunal system. * Benefits in %ind or extra salary, income tax and national insurance implications. &6 * 'orporation tax( 'apital gains groups, )G)* and rollo+er relief, group relief,consortium relief, o+erseas aspects( branch +s sub,'!'s,transfer pricing. * 'apital gains( Reliefs( rollo+er, holdo+er, gift, &&R and letting, o+erseas aspects. * nheritance tax( +aluation of shares, deed of +ariation, business property relief. * ncome tax( sole traders opening year rules, trading losses, benefits( car, accommodation, share incenti+e plans. * "#$( &artial exemption, land and buildings, group "#$ registration. * -cenarios( *ease +s. buy assets( net cost, company purchase of o.n shares, /$ +s 'G$ for gifts. &6 * ncorporation of a business including incorporation relief. * 'orporation tax including o+erseas aspects and controlled foreign companies. * &artnership. * Rent a room relief. * nheritance tax including business property relief. * &ersonal ser+ice companies or purchase of o.n shares. * n+estment in -0 -. * Remittance basis charge. &aper &6 1uestions 2 and 3 on the paper .ill be based around real life practical scenarios. 1uestion 2 .ill be for 45 mar%s and contain 6 professional mar%s a.arded for structuring the ans.er in the proper format and dealing professionally .ith the issues raised. n either of these first 3 7uestions 87uestion 3 .ill carry 35 mar%s9, .e are also li%ely to find 5 mar%s dealing .ith ethical issues such as confidentiality or non disclosure. /ere are : mar%s therefore that are little to do .ith technical competence in taxation in .hich candidates at this le+el should and must score highly; # fa+ourite area of the examining team deals .ith groups of companies, often .here losses, both trading and capital ha+e been experienced along .ith other chargeable gains arising and these need to be managed efficiently. # number of areas .here the candidate is as%ed to ad+ise on both actual and planned transactions .ould also be in+ol+ed. # ma<or issue here is dealing .ith changes in group structures such as a proposed ac7uisition of a target business .here either the client company may purchase the shares in the target company or the assets and trade of the target company. =a<or issues here for a buyer are access to the pre ac7uisition trading and capital losses of the target company through a share purchase as .ell as the tax .rite offs a+ailable on the purchase of intangibles .ithin an asset and trade purchase. $his may also test -tamp Duty and -tamp Duty *and $ax issues for buyers as .ell as "#$ issues especially the capital goods scheme

$he 7uestion may also ha+e an international aspect to it .ith ad+ice being re7uired on .hether to set up an o+erseas business as a subsidiary or branch, the application of the '!' legislation and .hether to ma%e the exemption election in respect of o+erseas branches. mportant points in the o.ner managed business life cycle lend themsel+es .ell to practical real life scenarios in+ol+ing multiple taxes. ncorporation may test ncome $ax, 'G$, 'orporation $ax, "#$ and -tamp Duty as the assets and trade of the indi+idual are transferred to a company. # tax efficient exit strategy for the o.ner manager is also .here the client .ould need .ell structured professional ad+ice. -hould the client sell his shares in his company possibly accepting shares and loan stoc% from the buyer as .ell as cash, or should the company sell its assets and trade and then distribute the net cash to the o.ner as either a capital or income distribution. f the taxpayer is a minority shareholder then only a share disposal is possible and a purchase of o.n shares by the company might be an attracti+e exit strategy. #nother fa+oured area of the examining team has been the o+erseas aspects of personal tax .here .e may ha+e to ad+ise on the implications for all the personal taxes of say a non U> domicile coming to the U> on a contract of employment or rene.ing a contract .hich may then in+ol+e a subse7uent remittance basis charge or no. e+en an increased charge. ?ther scenarios .ould include a U> resident accepting a contract of employment o+erseas and determining .hether their o+erseas income .ould be chargeable to U> tax and if so the application of D$R and,or someone returning from an o+erseas contract and see%ing ad+ice on .hen to dispose of +arious assets. @ith some candidates no. coming through to &6 ha+ing passed !6 .ith /$ in that syllabus .e may see a mo+e a.ay from standard computational exercises on the death of the taxpayer. #d+ice may be needed on .hen planned gifts should be made, in lifetime or on death and therefore in relation to lifetime gifts the taxpayerAs 'G$ position .ill need to be considered. $his brings into play the 'G$ and /$ reliefs .hich are consistently examined as students consistently get them .rong; 'andidates must %no. the conditions for reliefs to apply and must not confuse 'G$ and /$ reliefs B note particularly gift relief and entrepreneursA relief in 'G$ and B&R in /$. f a death estate is re7uired it is li%ely that there .ould be significant be7uests to charity bringing in the ne. reduced rate. &lanning after death .ould then in+ol+e the use of a deed of +ariation. n terms of ad+ising on tax efficient in+estments then, though high ris%, the sa+ings under the 0 - or ne. -eed 0 - are high and may be tested.