Question
2. You are requested by director of Moon Ltd to give advice on the tax implications of selling shares in a subsidiary company, making a
2. You are requested by director of Moon Ltd to give advice on the tax implications of selling shares in a subsidiary company, making a loan to another subsidiary company, and selling an intangible fixed asset. Moon Ltd: Moon Ltd owns 100% of the ordinary shares in Feld Ltd. Moon Ltd and Feld Ltd are UK resident trading companies. Both companies prepare accounts to 31 March annually. Neither company is a small or medium-sized enterprise (SME) for the purpose of transfer pricing. Moon Ltd sale of 7,500 ordinary shares (a 75% holding) in Mayr Ltd on 1 July 2019: Mayr Ltd is a UK resident trading company. The shares, which represent the whole of Moon Ltds shareholding, were sold to an unconnected purchaser for 790,000. Moon Ltd had acquired these shares on 1 March 2012 for 455,000. Moon Ltd had sold a warehouse to Mayr Ltd on 8 April 2014 for its market value on that date of 165,000. Moon Ltd had purchased the warehouse on 12 May 2012 for 129,000. Mayr Ltd still owned the warehouse on 1 July 2019. Moon Ltd loan to Feld Ltd: Moon Ltd will make a loan of 450,000 to Feld Ltd on 1 April 2020. Feld Ltd will use the loan to purchase goodwill and office premises for use in its business, and 70% of the ordinary share capital of Durn Ltd. The cost of these acquisitions is as follows: Goodwill 68,000 Office premises 137,000 70% shareholding in Durn Ltd 245,000 Moon Ltd will charge interest at the rate of 7% per year on this loan. Feld Ltd has been offered a loan of 450,000 from a bank at an interest rate of 10% per annum. In the year ending 31 March 2021, Feld Ltd will have a trading profit of 587,000 and interest receivable of 48,100. Moon Ltd proposed sale of a patent: Moon Ltd will sell a patent to Durn Ltd on 3 May 2020 for 72,000. Moon Ltd purchased the patent for 60,000 on 3 May 2015. The tax written down value of the patent on 3 May 2020 will be 30,000. Moon Ltd has always used the patent in its business. Calculate amount deductable from Feld Ltd trading income in respect of interest charged on loan by Moon Ltd to Field ltd as per UK tax laws 2019?
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