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ading company incorporated and tax resident in Singapore. It has accounting ending 31 October. The following table shows the shareholders of ABC Singapore Pte Ltd

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ading company incorporated and tax resident in Singapore. It has accounting ending 31 October. The following table shows the shareholders of ABC Singapore Pte Ltd (ABC) and their respective percentage shareholdings at the various dates are as follows: Number of issued shares of ssl each, fully paid up as nt: 31.10.2014 31.12.2014 31.10.2015 31.12.2015 31.10.2016 31.12.2016 31.12.2019 & 1.1.2020 Sally 26,000 26,000 26.000 26,000 Pte 26,000 26,000 26,000 Ltd ded and tax resident in Singapore. It has accounting owing table shows the shareholders of ABC Singapore Pte Ltd (ABC) percentage shareholdings at the various dates are as follows: Number of issued shares of SS1 each, fully paid up as at: 31.10.2014 31.12.2014 31.10.2015 31.12.2015 31.10.2016 31.12.2016 31.12.2019 & Sally 1.1.2020 26,000 26,000 26,000 Pte 26,000 26,000 26,000 26,000 Ltd Mr. 22.000 22,000 22,000 X 22,000 21,000 20,000 11,000 Mr. 31.10.2015 31.12.2015 31.10.2016 31.12.2016 31.12.2019 Sally 26.000 1.1.2020 26.000 Pte 26.000 26.000 26,000 Ltd 26.000 26,000 Mr. 22,000 22,000 x 22,000 22,000 21,000 20,000 11,000 Mr. Y 1,000 2,000 11,000 48,000 48,000 48,000 48,000 Sally Pte Ltd (SPL) is incorporated in Singapore and has its board of directors meeting in Thailand. 48,000 48,000 48,000 It has the same accounting year end as ARCA 1,000 2.000 48.000 11.000 18.000 Sally Pte Ltd (SPI) is incorporated in Singapore and has its board of directors meeting in Thailand 48.000 48,000 48,000 48.000 48.000 It has the same accounting year end as ABC. As at 31 October 2014, SPL was 60% beneficially owned by Mr. W and 40% beneficially owned by Mr. X On 15 July 2013. Mr W transferred his entire beneficial ownership in SPL to Mr. Z. All changes to the shareholders and their shareholdings to date have been reflected in the table above ABC has the following umabsorbed loss items: Unabsorbed tax losses for the year ended 31 October 2014 - $52,450 Unabsorbed capital allowances for the Year of Assessment 2014 - $12,800 Unabsorbed donations made on 31 October 2016 - $11,000 Unabsorbed tax losses for the year ended 31 October 2015 - $39,700 SPL has the following unabsorbed loss ite SPL's unabsorbed tax losses for the Year of Assessment 2014 - $130,000 SPL's unabsorbed capital allowances for the Year of Assessment 2020 - $10,000 bsorbed loss items: Unabsorbed tax losses for the year ended 31 October 2014 - $52,450 Unabsorbed capital allowances for the Year of Assessment 2014 - $12.800 Unabsorbed donations made on 31 October 2016 - $11,000 Unabsorbed tax losses for the year ended 31 October 2015 - $39.700 SPL has the following unabsorbed loss items: SPL's unabsorbed tax losses for the Year of Assessment 2014 - $130,000 SPL's unabsorbed capital allowances for the Year of Assessment 2020 - $10,000 (a) Discuss whether ABC is entitled to claim group relief for SPL's loss items for YA 2020. Statelexplain your reasons, workings and assumptions (if any) clearly. (4 Marks) (b) Determine whether ABC can utilise the unabsorbed tax losses, capital allowances and donations to offset against its YA 2020's taxable income, including showing the relevant dates and their respective shareholders and shareholdings. State/explain your reasons, workings and assumptions (if any) clearly. (11 marks) Paragraph BIU ading company incorporated and tax resident in Singapore. It has accounting ending 31 October. The following table shows the shareholders of ABC Singapore Pte Ltd (ABC) and their respective percentage shareholdings at the various dates are as follows: Number of issued shares of ssl each, fully paid up as nt: 31.10.2014 31.12.2014 31.10.2015 31.12.2015 31.10.2016 31.12.2016 31.12.2019 & 1.1.2020 Sally 26,000 26,000 26.000 26,000 Pte 26,000 26,000 26,000 Ltd ded and tax resident in Singapore. It has accounting owing table shows the shareholders of ABC Singapore Pte Ltd (ABC) percentage shareholdings at the various dates are as follows: Number of issued shares of SS1 each, fully paid up as at: 31.10.2014 31.12.2014 31.10.2015 31.12.2015 31.10.2016 31.12.2016 31.12.2019 & Sally 1.1.2020 26,000 26,000 26,000 Pte 26,000 26,000 26,000 26,000 Ltd Mr. 22.000 22,000 22,000 X 22,000 21,000 20,000 11,000 Mr. 31.10.2015 31.12.2015 31.10.2016 31.12.2016 31.12.2019 Sally 26.000 1.1.2020 26.000 Pte 26.000 26.000 26,000 Ltd 26.000 26,000 Mr. 22,000 22,000 x 22,000 22,000 21,000 20,000 11,000 Mr. Y 1,000 2,000 11,000 48,000 48,000 48,000 48,000 Sally Pte Ltd (SPL) is incorporated in Singapore and has its board of directors meeting in Thailand. 48,000 48,000 48,000 It has the same accounting year end as ARCA 1,000 2.000 48.000 11.000 18.000 Sally Pte Ltd (SPI) is incorporated in Singapore and has its board of directors meeting in Thailand 48.000 48,000 48,000 48.000 48.000 It has the same accounting year end as ABC. As at 31 October 2014, SPL was 60% beneficially owned by Mr. W and 40% beneficially owned by Mr. X On 15 July 2013. Mr W transferred his entire beneficial ownership in SPL to Mr. Z. All changes to the shareholders and their shareholdings to date have been reflected in the table above ABC has the following umabsorbed loss items: Unabsorbed tax losses for the year ended 31 October 2014 - $52,450 Unabsorbed capital allowances for the Year of Assessment 2014 - $12,800 Unabsorbed donations made on 31 October 2016 - $11,000 Unabsorbed tax losses for the year ended 31 October 2015 - $39,700 SPL has the following unabsorbed loss ite SPL's unabsorbed tax losses for the Year of Assessment 2014 - $130,000 SPL's unabsorbed capital allowances for the Year of Assessment 2020 - $10,000 bsorbed loss items: Unabsorbed tax losses for the year ended 31 October 2014 - $52,450 Unabsorbed capital allowances for the Year of Assessment 2014 - $12.800 Unabsorbed donations made on 31 October 2016 - $11,000 Unabsorbed tax losses for the year ended 31 October 2015 - $39.700 SPL has the following unabsorbed loss items: SPL's unabsorbed tax losses for the Year of Assessment 2014 - $130,000 SPL's unabsorbed capital allowances for the Year of Assessment 2020 - $10,000 (a) Discuss whether ABC is entitled to claim group relief for SPL's loss items for YA 2020. Statelexplain your reasons, workings and assumptions (if any) clearly. (4 Marks) (b) Determine whether ABC can utilise the unabsorbed tax losses, capital allowances and donations to offset against its YA 2020's taxable income, including showing the relevant dates and their respective shareholders and shareholdings. State/explain your reasons, workings and assumptions (if any) clearly. (11 marks) Paragraph BIU

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