2.Company tax liabilities in situations involving further overseas and group aspects and in relation to special types of company, and the application of additional exemptions and reliefs.
2a) The contents of the Paper F6 study guide, for company tax, under headings:
- C1 The scope of company tax
- C2 Profits chargeable to company tax
- C3 The comprehensive computation of company tax liability
- C4 The use of exemptions and reliefs in deferring and minimising company tax liabilities.
2b) The scope of company tax:
- Identify and calculate company tax for companies with investment business
- Understand the tax implications of a company being wound up, liquidated or de-registered
- Advise on the tax implications of a purchase by a company of its own shares
- Explain the tax special rules applying to company formations, share for share transactions, intra group transactions and liquidation distributions
- Identify personal service companies and advise on the tax consequences of being a personal service company
- Explain the anti-avoidance provisions
2c) Profits chargeable to company tax:
- Identify qualifying research and development expenditure
- Recognise the tax treatments of intangible assets
- Advise on the impact of the transfer pricing and thin capitalisation rules on companies
- Advise on the restriction on the use of losses on a change in ownership of a company.
2d) The comprehensive computation of company tax liability:
Evaluate the meaning and implications of a permanent establishment
Advise on the tax position of overseas companies trading in South Africa.