you have received a mail from mita the owner and managing director of porth ltd. The following are extracts of mail.

calculate the corporate tax liability of PE of Rub Ltd in tiron and also calculate profit exemption election of PE from UK tax as per Finance act 2019 U.K

10% Sale of 4,000 ordinary shares in Porth Ltd On 1 May 2020, I am going to sell 4,000 shares in Porth Ltd to my brother, Ned. I note from the work you have already done that the current market value of these shares is 260,000. However, because I am keen to get Ned involved, I have agreed a price of 200,000. Ned, who is UK resident, will sign the claim for capital gains tax gift relief in respect of this sale. Joint venture - Quod Ltd On 1 April 2020, I shall incorporate a new company, Quod Ltd. On that day, Quod Ltd will register for value added tax (VAT) and begin to trade. It will develop a range of products over the next few years, The planned ownership of the ordinary share capital of Quod Ltd is as follows: Porth Ltd 60% Either Mr Berm or Mr Berm's company, BJB Ltd 30% CX Ltd Porth Ltd, BJB Ltd and CX Ltd are UK resident companies. Mr Berm is resident in the UK. Quod Ltd - financial information I have calculated Quod Ltd's budgeted tax adjusted trading loss for the year ending 31 March 2021 to be 44,000. When calculating the loss, deducted the whole of the costs attributable to scientific research amounting to 102,000 (note 1). I also deducted 1,000 in respect of the Cloque brand (note 2), as it will be amortised over a period of 35 years. Note 1: Scientific research costs Equipment and computer hardware 27,500 Materials 21,000 Rent 17,400 Electricity and water 6,600 Staff costs 29,500 102,000 The rent is an appropriate allocation of the rent payable for Quod Ltd's premises for the year. All of the staff costs relate to employees of Quod Ltd with the exception of 7,000 paid to an external contractor provided by an unconnected company Note 2: Purchase of the Cloque brand On 1 April 2020, Quod Ltd will purchase the Cloque brand for 35,000. Advice will then be required on how to develop this brand through the use of social media. It is intended that Quod Ltd will purchase this advice from a company based outside the EU (in a country where the rate of VAT is 9%) rather than as a standard rated supply from a VAT registered supplier based in the UK Acquisition of Ryb Ltd On 1 May 2020, Porth Ltd will purchase the whole of the ordinary share capital of Ryb Ltd. For the purposes of UK tax, Ryb Ltd is resident in the UK, Ryb Ltd trades through a permanent establishment (PE) in the country of Tirona. Ryb Ltd's budgeted taxable trading profit for the year ending 31 March 2021, all of which relates to its activities in Tirona, is 75,000. Ryb Ltd has no other source of taxable income and is not expected to make any chargeable gains during the year. Once we are confident of the profitability of the PE in Tirona, it is intended that Ryb Ltd will establish Pes in two other countries Additional information in respect of Porth Ltd, Quod Ltd and Ryb Ltd Porth Ltd Mita owns the whole of the ordinary share capital of Porth Ltd, which is an unquoted trading company. Mita began trading as an unincorporated business on 1 June 2012. On 1 April 2015, when the assets of her business were worth 120,000, she incorporated her business by selling all of the assets to Porth Ltd in exchange for 10,000 ordinary shares. This sale resulted in total chargeable gains of 37,400, all of which were relieved by incorporation relief. Porth Ltd prepares accounts to 31 March each year. It does not own any assets other than those which are used in its trade. Quod Ltd Quod Ltd will be a small enterprise for the purposes of the additional tax relief available for expenditure on research and development. I have already established that the research to be carried out by Quod Ltd will qualify for this relief. Quod Ltd WILL NOT surrender any part of the loss in return for a cash refund from HM Revenue and Customs (HMRC) Ryb Ltd Ryb Ltd has not made an election to exempt the profits of its overseas permanent establishment (PE) from UK tax The rate of corporation tax in the country of Tirona is 14%. Other than that, the tax system in Tirona is the same as that in the UK. There is no double tax treaty between the UK and Tirona. Please carry out the following work: (a) Sale of 4,000 shares in Porth Ltd on 1 May 2020 Calculate Mita's capital gains tax (CGT) liability in respect of this proposed sale to Ned assuming all available reliefs will be claimed. Mita is resident in the UK. You should assume she will be a higher rate taxpayer in the tax year 2020/21 and that the CGT annual exempt amount WILL NOT be available to her. (b) Quod Ltd Explain the tax deduction which will be available to Quod Ltd in respect of the scientific research costs of 102,000 to be incurred in the year ending 31 March 2021. Explain the tax treatment of the proposed purchase of the Cloque brand (an intangible fixed asset) for 35,000. Calculate the amended budgeted tax adjusted trading loss for Quod Ltd for the year ending 31 March 2021 taking into account the explanations requested above. Explain how much of Quod Ltd's amended budgeted trading loss will be available for use by Porth Ltd. Explain the value added tax (VAT) implications of Quod Ltd purchasing advice from the overseas supplier, rather than the one based in the UK. (c) Ryb Ltd Explain why the profits of Ryb Ltd are subject to UK corporation tax Calculate Ryb Ltd's expected UK corporation tax liability for the year ending 31 March 2021 based on the information available, Discuss the advantages and disadvantages of Ryb Ltd making an election to exempt the profits of its PE in Tirona from UK tax. Tax manager 10