Final_exam_2009试题

  • 格式:doc
  • 大小:37.50 KB
  • 文档页数:2

AC.423 Tax Problem
1st Semester 2009
Final Examination

Please answer ALL questions (20) points for each question)
1. For accounting period ending 2008, Alpha Ltd., a company incorporated under Thai
law, has following income:

1. Sale of goods to Beta Ltd., a company incorporated under Thai law
=10,000,000 Baht

2. Interest from money lent to Beta Ltd. = 500,000 Baht
3. etc…….

From an audit carried out by a Revenue officer, it was found that the market price for
the goods sold to Beta Ltd. is 15,000,000 Baht. Furthermore, interest earned was
charged below market value.

As a tax consultant, please advise Alpha Ltd. on the tax implications based on the
provisions in the Revenue Code. Please also offer your view on the applicable laws,
or the lack of it.

2. From the table below, assuming a company was granted BoI for 5 years from 2544-
2548, please explain how to calculate loss carried forward for 5 years after the
promotional period ends? Please discuss any relevant Board of Revenue Ruling
decision.

Accounting Period Profits Loss Losses carried forward Corporate
Income Tax
2544 - 10 - -
2545 - 5 - -
2546 1 - - -
2547 1 - - -
2548 5 - - -
2549 5 - - -
2550 2 - - -
2551 2 - - -
3. For Value Added Tax (VAT) purpose, what does the term ‘Reverse charge
mechanism’ refer to? How does it work? Is there any problem in the payment of
VAT?

Please answer TWO of the following questions (20 points each)
1. What does the term ‘Thin capitalisation’ refer to? What are tax problems from the
practice of Thin capitalisation? What are your suggestion to solve the problem of
Thin Capitalisation?

2. A Ltd., a company incorporated under Thai law, carries on consultancy business in
Thailand. Recently, it expands its business and it now has two branches abroad, one
in Singapore and the other in Vietnam. A Ltd. uses a calendar year as its accounting
period. At the end of each accounting period, it has to bring profits from its overseas
branches into its corporate income tax computation.

From the above scenario, what are tax problems, if any, that you can see? Please
discuss whether there is any remedy under Thai Revenue Code.

3. Zebra Ltd, a company incorporated under Thai law, filed Corporate Income Tax for
an accounting period ending 2008, and paid 1 million Baht in tax. Last month, it
received a notice from a Revenue officer to adjust its profits, and was told that it had
underpaid tax in an amount of 200,000 Baht. Please advise Zebra Ltd., based on what
you have studied, regarding ways and means to end the dispute with the Revenue
officer.

4. What does the term ‘Tax Sparing’ mean? Does it pose any problem to Thai taxation?
If so, please explain.