ACCA P6(China)历年考试真题及答案大全(2004年-2008年)

ACCA P6(China)历年考试真题及答案大全(2004年-2008年)

包含(2004年-2008年) ACCA P6(China)历年考试真题及答案,文件列表如下:

Advanced Taxation(China)


Time allowed 3 hours
This paper is divided into two sections
Section A BOTH questions are compulsory and MUST be
Section B TWO questions ONLY to be answered
Tax rates and allowances are on pages 2 – 3

Section A – BOTH questions are compulsory and MUST be attempted
1 Company K is a wholly owned Chinese holding company which was set up by a US multi-national corporation in
2003 for the purpose of overseeing the operations of joint ventures set up in Beijing, Shanghai, Qindgao and
Chengdu. The total investments in China held by Company K amount to RMB1,500,000,000. In 2004, Company
K received a total dividend of RMB3,000,000 from the joint ventures in China.
Company K has employed a team of experienced management to handle the day-to-day management of their equity
interests in the joint ventures. On a needed basis, the management team also provides technical support and training
to the joint ventures. In addition, all sales and marketing activities are centralised at Company K. So far, Company K
has not allocated any expenses incurred for the technical support and training or the sales and marketing activities to
the joint ventures.
In view of the growing business opportunities in China, the general manager of Company K is considering expanding
the business scope of Company K such that Company K will also be engaged in general trading business for goods
produced by some third party manufacturers outside China. In this connection, he called a meeting with his in-house
tax counsel. In the meeting, he was advised that the contemplated trading business would not be allowed under the
relevant Chinese rules and regulations. In addition, he was advised that there were a few tax issues pertaining to the
existing operations, which should be attended to as soon as possible. The general manager was very puzzled and
would like a second opinion with regard to these matters.
(a) Identify the potential tax issues pertaining to the technical support and training as well as sales and
marketing activities under the existing operations of Company K assuming Company K has not taken into
consideration any tax adjustments from a Chinese tax perspective. (5 marks)
(b) Explain briefly the tax implications of:
(i) the dividend income received in 2004; and (3 marks)
(ii) the expenses of the day-to-day management activities performed with respect to the equity interests in
the joint ventures. (14 marks)
(c) As the joint ventures commenced to make a profit in 2004, the general manager is considering allocating the
expenses incurred for technical support and training, as well as for sales and marketing activities amongst the
joint ventures from 2006 onwards.
Advise the general manager of the tax implications of this proposal, together with any actions that Company
K should take. (18 marks)
(40 marks)