BPT exam review questions and
answers
2) Automatic UK test - UK if satisfies any. Sufficient ties if not satisfied.
1) Physically present in UK >6 months
2) At least 91 consecutive days (30 in tax yr) when he has home in UK, no home
o/s, >30 days in UK home
3) Full-time UK work test: >35 hrs/week; no periods >30 days not working; >75%
days working in UK; >1 day in tax yr when working >3 hrs UK
Exam technique (6) - -What
-Why (conditions)
-# as
-Impact (tax reduction)
-Claim payment/payment date (exact date)
-Application (anything unusual)
ER (7) - Whole point is ST disposing of biz, must have owned >1 year. Applies to:
-All or part of ST biz [owned at least one year; selling entire holding/interest]
-Assets of ST biz w/in 3 yrs of cessation
-Shares if FTTW (state)
-10%
-Subject to £10m lifetime limit
-Claim within 12m from 31 Jan following tax yr relief claimed
R&D SMEs (3) - -FYA on capex
,BPT exam review questions and
answers
-Revex: 230% tax reduction
-Can claim 14.5% tax credit, lower of 230% and adjusted trading loss (after loss
relief claims)
Split year conditions (e.g. if UK res at start of year) (2) - -Leaves for work
-Not UK resident next year
Share buyback: Automatically capital if - (6) - -Unquoted trade co
-Benefit of trade
-UK res
-Held for prior 5 years (3 if inherited)
-Reduces to <75% of pre-sale s/holding
-Reduce s/holding to <30% of total shares in company
CFC exemptions (5) - -Tax >75% UK tax
-Exempt period (12 mo to restructure - otherwise taxed from charged from
acquistion)
-Excluded 'good' territories
-Low profits (<£500k, or £50k non-trading)
-Low profit margin (<10%)
CFC gateway (1 + 3) - -Profits attributable to UK activities
...Will not pass t/ gateway if:
, BPT exam review questions and
answers
-CFC has no assets or risks deriving from tax planning schemes
-None of CFC's assets or risks managed from UK
-CFC has ability to manage own biz if UK management of assets and risks were to
stop
Diverted profits tax (DPT) (5) - Either:
1) Activities to avoid a Co being classed as UK PE. (N/a if UK rev <£10m)
2) Arrangements that lack economic substance - i.e. profits are shifted to lower tax
regime
-May escape charge if lower tax rate >80% of UK rate (no effective tax mismatch)
-DPT is 25% on diverted profits
-DPT not self-assessed; must notify HMRC within three months of the relevant AP
1) Automatic O/s test - A) Non-UK if satisfies any
1) UK res 1 of last 3 years and <16 days UK in current tax year
2) Not UK res in last 3 yrs, spends <46 days UK in current tax yr
3) Works 35 hrs week o/s, no gaps > 30 days in o/s work, no more than 30 days of
UK work, spends <91 days UK
O/S CGT (2) - -Gains on UK res prop from 6/4/15 always taxable
-Temporary non-residence (leave UK for <5 yrs and come back)
ST: CY/PY loss relief (5) - -Any order (CY/PY)
-Net income... don't use if wasting PA
answers
2) Automatic UK test - UK if satisfies any. Sufficient ties if not satisfied.
1) Physically present in UK >6 months
2) At least 91 consecutive days (30 in tax yr) when he has home in UK, no home
o/s, >30 days in UK home
3) Full-time UK work test: >35 hrs/week; no periods >30 days not working; >75%
days working in UK; >1 day in tax yr when working >3 hrs UK
Exam technique (6) - -What
-Why (conditions)
-# as
-Impact (tax reduction)
-Claim payment/payment date (exact date)
-Application (anything unusual)
ER (7) - Whole point is ST disposing of biz, must have owned >1 year. Applies to:
-All or part of ST biz [owned at least one year; selling entire holding/interest]
-Assets of ST biz w/in 3 yrs of cessation
-Shares if FTTW (state)
-10%
-Subject to £10m lifetime limit
-Claim within 12m from 31 Jan following tax yr relief claimed
R&D SMEs (3) - -FYA on capex
,BPT exam review questions and
answers
-Revex: 230% tax reduction
-Can claim 14.5% tax credit, lower of 230% and adjusted trading loss (after loss
relief claims)
Split year conditions (e.g. if UK res at start of year) (2) - -Leaves for work
-Not UK resident next year
Share buyback: Automatically capital if - (6) - -Unquoted trade co
-Benefit of trade
-UK res
-Held for prior 5 years (3 if inherited)
-Reduces to <75% of pre-sale s/holding
-Reduce s/holding to <30% of total shares in company
CFC exemptions (5) - -Tax >75% UK tax
-Exempt period (12 mo to restructure - otherwise taxed from charged from
acquistion)
-Excluded 'good' territories
-Low profits (<£500k, or £50k non-trading)
-Low profit margin (<10%)
CFC gateway (1 + 3) - -Profits attributable to UK activities
...Will not pass t/ gateway if:
, BPT exam review questions and
answers
-CFC has no assets or risks deriving from tax planning schemes
-None of CFC's assets or risks managed from UK
-CFC has ability to manage own biz if UK management of assets and risks were to
stop
Diverted profits tax (DPT) (5) - Either:
1) Activities to avoid a Co being classed as UK PE. (N/a if UK rev <£10m)
2) Arrangements that lack economic substance - i.e. profits are shifted to lower tax
regime
-May escape charge if lower tax rate >80% of UK rate (no effective tax mismatch)
-DPT is 25% on diverted profits
-DPT not self-assessed; must notify HMRC within three months of the relevant AP
1) Automatic O/s test - A) Non-UK if satisfies any
1) UK res 1 of last 3 years and <16 days UK in current tax year
2) Not UK res in last 3 yrs, spends <46 days UK in current tax yr
3) Works 35 hrs week o/s, no gaps > 30 days in o/s work, no more than 30 days of
UK work, spends <91 days UK
O/S CGT (2) - -Gains on UK res prop from 6/4/15 always taxable
-Temporary non-residence (leave UK for <5 yrs and come back)
ST: CY/PY loss relief (5) - -Any order (CY/PY)
-Net income... don't use if wasting PA
