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1. Arcadia Ltd (‘Arcadia’) is a UK tax resident company that carries on two trades:
(1) manufacturing computers in the UK (“Trade A”), and (2) selling computers via retail shops in the UK (“Trade B”).
2. Arcadia also owns capital assets that are situated in Utopia (as referred to below).
3. The shareholders (and their shareholdings in Arcadia in respect of 100 issued shares) are: Sam (20 shares), Samantha (20 shares), Joe (40 shares), James (20 shares) (collectively the “Shareholders”). Each of the shareholders is UK tax resident.
4. Each of the shareholders acquired their holdings in Arcadia for a price per share of £1. The market value of each share is currently £10,000.
5. The Shareholders own the same number of shares in Super Arcadia, as they do in Arcadia. Super Arcadia is an entity incorporated under the law of a foreign country. Super Arcadia is subject to UK corporate taxation because its central management & control is located in the UK.
6. You have been appointed to advise all of the Shareholders and Arcadia regarding the following scenarios:
a. The tax charges and available tax reliefs under the Taxation of Chargeable Gains Act 1992 that arise if the shares in Arcadia are acquired from each of the shareholders by Super Match Ltd (the purchase price to be satisfied by the issue of shares in Super Match Ltd).
b. The tax charges and available tax reliefs under the Taxation of Chargeable Gains Act 1992 that arise if there is a members voluntary liquidation of Arcadia, with (i) Trade A being transferred to NewCo A (which will be wholly owned by Sam and Samantha); and (ii) Trade B being transferred to NewCo B (which will be wholly owned by Joe and James).
c. What factors will HMRC take into account in determining whether Super Arcadia is a company for the purposes of section 139 of the Taxation of Chargeable Gains Act 1992?
d. Arcadia owns the capital assets, identified below, which are located in Utopia. Arcadia will sell the assets for market value to an unconnected company that is tax resident in Utopia. The UK and Utopia have entered into a double taxation agreement which is identical to the OECD Model Tax Convention. Utopia imposes tax on the disposal of capital
assets at 25% of the capital gain (which is collected via the purchaser).
Advise Arcadia in respect of whether the UK and/or Utopia will have the right to tax the disposal proceeds of each of the following assets (and whether the UK will give any UK tax credit for tax incurred in Utopia):-
i. The disposal of real estate situated in Utopia for £10million (Arcadia paid an acquisition cost of £1,000);
ii. The disposal of equipment for £1million used by a permanent establishment situated in Utopia (Arcadia paid an acquisition cost of £100,000);
iii. The disposal of patent rights registered in Utopia for £5million (Arcadia paid an acquisition cost of £1million);
iv. The disposal of shares in a company incorporated and tax resident in Utopia for £50million (Arcadia paid an acquisition cost of £1);
v. The disposal of an aircraft which is effectively operated and managed in Utopia for £1million (Arcadia paid an acquisition cost of £500,000).
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Do not include a bibliography at the end of the MOA. As the MOA is not an academic paper, we do not require bibliographies from students.

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