(b) Draft a report as at today’s date advising Cutlass Inc on its proposed activities. The report should cover the
following issues:
(i) The rate at which the profits of Cutlass Inc will be taxed. This section of the report should explain:
– the company’s residency position and what Ben and Amy would have to do in order for the company
to be regarded as resident in the UK under the double tax treaty;
– the meaning of the term ‘permanent establishment’ and the implications of Cutlass Inc having a
permanent establishment in Sharpenia;
– the rate at which the profits of Cutlass Inc will be taxed on the assumption that it is resident in the
UK under the double tax treaty and either does or does not have a permanent establishment in
Sharpenia. (9 marks)
正确答案：(b) Report to the management of Razor LtdTo The management of Razor LtdFrom Tax advisersDate 6 June 2007Subject The proposed activities of Cutlass Inc(i) Rate of tax on profits of Cutlass IncWhen considering the manner in which the profits of Cutlass Inc
