(b) The tax relief available in respect of the anticipated trading losses, together with s

Question

(b) The tax relief available in respect of the anticipated trading losses, together with supporting calculations and

a recommended structure for the business. (16 marks)

Answer 1

正确答案：

 

Aral Ltd owned by Banda
The losses would have to be carried forward and deducted from the trading profits of the year ending 30 June 2010.
Aral Ltd cannot offset the loss in the current period or carry it back as it has no other income or gains.
Aral Ltd owned by Flores Ltd
The two companies will form. a group relief group if Flores Ltd owns at least 75% of the ordinary share capital of Aral
Ltd. The trading losses could be surrendered to Flores Ltd in the year ending 30 June 2008 and the year ending
30 June 2009. The total tax saved would be ￡11,079 ((￡38,696 + ￡19,616) x 19%)
Recommended structure
The Aral business should be established in a company owned by Flores Ltd.
This will maximise the relief available in respect of the trading losses and enable relief to be obtained in the period in
which the losses are incurred.
Tutorial note
The whole of the loss for the period ending 30 June 2008 can be surrendered to Flores Ltd as it is less than that
company’s profit for the corresponding period, i.e. ￡60,000 (￡120,000 x 6/12).