Question
Workhorse Limited is incorporated in the UK, and trades through, a permanent establishment in the country of Zakusia. It has UK taxable trading profits of
Workhorse Limited is incorporated in the UK, and trades through, a permanent establishment in the country of Zakusia. It has UK taxable trading profits of £800,000 for the year ended 31st June 2020 and additional trading profits of £400,000 from its Zakusia operations. The rate of corporation tax in Zakusia is 13%. There is no tax treaty in place between UK and Zakusia.
Workhorse Limited has not made an election to exempt its overseas trading profits from UK tax.
Required:
(i) Assuming that the profits of Workhorse Limited remain the same in future years explain, with supporting calculations, if an election to exempt its overseas profits from UK tax should be made.
(ii) Explain the key disadvantages of an election to exempt overseas profits from UK tax.
(iii) Discuss a different business structure that Workhorse Limited could use in regard to its operations in Zakusia, comparing the advantages and disadvantages with its current structure.
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