Advanced Taxation – United Kingdom (ATX-UK)

Advanced
Taxation –
United Kingdom
(ATX-UK)
Syllabus and study guide

June 2022 to March 2023

Designed to help with planning study and to provide

detailed information on what could be assessed in any
examination session

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 Advanced Taxation – United Kingdom (ATX-UK)

Contents
1. Intellectual levels .....................................3
2. Learning hours and education recognition
...................................................................3
3. The structure of ACCA qualification ........4
4. Guide to ACCA examination structure and
delivery mode .............................................5
5. Guide to ACCA examination assessment 7
6. Relational diagram linking Advanced
Taxation – United Kingdom (ATX-UK) with
other exams ................................................8
7. Approach to examining the syllabus ........8
8. Introduction to the syllabus......................9
9. Main capabilities ...................................10
10. The syllabus ........................................11
11. Detailed study guide............................13
12. Summary of changes to Advanced
Taxation (ATX-UK) ....................................23

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 Advanced Taxation – United Kingdom (ATX-UK)

1.Intellectual levels 2.Learning hours and

The syllabus is designed to progressively
education recognition
broaden and deepen the knowledge, skills
The ACCA qualification does not prescribe
and professional values demonstrated by
or recommend any particular number of
the student on their way through the
learning hours for examinations because
qualification.
study and learning patterns and styles vary
greatly between people and organisations.
The specific capabilities within the detailed
This also recognises the wide diversity of
syllabuses and study guides are assessed at
personal, professional and educational
one of three intellectual or cognitive levels:
circumstances in which ACCA students find
themselves.
Level 1: Knowledge and
comprehension
As a member of the International Federation
Level 2: Application and analysis
of Accountants, ACCA seeks to enhance the
Level 3: Synthesis and evaluation
education recognition of its qualification on
both national and international education
Very broadly, these intellectual levels relate
frameworks, and with educational authorities
to the three cognitive levels at which the
and partners globally. In doing so, ACCA
Applied Knowledge, the Applied Skills and
aims to ensure that its qualification is
the Strategic Professional exams are
recognised and valued by governments,
assessed.
regulatory authorities and employers across
all sectors. To this end, ACCA qualification
Each subject area in the detailed study
is currently recognised on the education
guide included in this document is given a 1,
frameworks in several countries. Please
2, or 3 superscript, denoting intellectual
refer to your national education framework
level, marked at the end of each relevant
regulator for further information.
learning outcome. This gives an indication of
the intellectual depth at which an area could
Each syllabus is organised into main subject
be assessed within the examination.
area headings which are further broken
However, while level 1 broadly equates with
down to provide greater detail on each area.
Applied Knowledge, level 2 equates to
Applied Skills and level 3 to Strategic
Professional, some lower level skills can
continue to be assessed as the student
progresses through each level. This reflects
that at each stage of study there will be a
requirement to broaden, as well as deepen
capabilities. It is also possible that
occasionally some higher level capabilities
may be assessed at lower levels.

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 Advanced Taxation – United Kingdom (ATX-UK)

3.The structure of ACCA qualification

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 Advanced Taxation – United Kingdom (ATX-UK)

Strategic Professional
4.Guide to ACCA Strategic Business Leader is ACCA’s case
study examination at Strategic Professional
examination structure and and is examined as a closed book exam of
delivery mode four hours, including reading, planning and
reflection time which can be used flexibly
The pass mark for all ACCA Qualification within the examination. There is no pre-seen
exams is 50%. information and all exam related material,
including case information and exhibits are
The structure and delivery mode of available within the examination. Strategic
examinations varies. Business Leader is an exam based on one
main business scenario which involves
Applied Knowledge candidates completing several tasks within
The Applied Knowledge examinations which additional material may be introduced.
contain 100% compulsory questions to All questions are compulsory and each
encourage candidates to study across the examination will contain a total of 80
breadth of each syllabus. These are technical marks and 20 Professional Skills
assessed by a two-hour computer based marks.
examination.
The other Strategic Professional exams are
Applied Skills all of three hours and 15 minutes duration.
The Corporate and Business Law exam is a All contain two sections and all questions
two-hour computer-based objective test are compulsory. These exams all contain
examination for English and Global. four professional marks.

For the format and structure of the From 2020, Strategic Professional exams
Corporate and Business Law or Taxation became available by computer based
variant exams, refer to the ‘Approach to examination. More detail regarding what is
examining the syllabus’ section of the available in your market will be on the ACCA
relevant syllabus and study guide. global website.

The other Applied Skills examinations (PM, With Applied Knowledge and Applied Skills
TX-UK, FR, AA, and FM) contain a mix of exams now assessed by computer based
objective and longer type questions with a exam, ACCA is committed to continuing on
duration of three hours for 100 marks. These its journey to assess all exams within the
are assessed by a three hour computer- ACCA Qualification using this delivery mode.
based exam. Prior to the start of each exam
there will be time allocated for students to be The question types used at Strategic
informed of the exam instructions. Professional again require students to
effectively mimic what they would do in the
The longer (constructed response) question workplace. These exams offer ACCA the
types used in the Applied Skills exams opportunity to focus on the application of
(excluding Corporate and Business Law) knowledge to scenarios, using a range of
require students to effectively mimic what tools – spreadsheets, word processing and
they do in the workplace. Students will need presentations - not only enabling students to
to use a range of digital skills and demonstrate their technical and professional
demonstrate their ability to use spread skills but also their use of the technology
sheets and word processing tools in available to today’s accountants.
producing their answers, just as they would
use these tools in the workplace. These
assessment methods allow ACCA to focus
on testing students’ technical and application
skills, rather than, for example, their ability to
perform simple calculations.

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 Advanced Taxation – United Kingdom (ATX-UK)

Time management
ACCA encourages students to take time to
read questions carefully and to plan answers
but once the exam time has started, there
are no additional restrictions as to when
candidates may start producing their
answer.

Time should be taken to ensure that all the

information and exam requirements are
properly read and understood.

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 Advanced Taxation – United Kingdom (ATX-UK)

5.Guide to ACCA generally examine the Finance Act which

was passed in the previous year. Therefore,
examination assessment exams falling in the period 1 June 2022 to
31 March 2023 will examine the Finance Act
ACCA reserves the right to examine any 2021 and any examinable legislation which
learning outcome contained within the study is passed outside of the Finance Act before
guide. This includes knowledge, techniques, 31 May 2021.
principles, theories, and concepts as
specified. For the financial accounting, audit For additional guidance on the examinability
and assurance, law and tax exams except of specific tax rules and the depth in which
where indicated otherwise, ACCA will they are likely to be examined, reference
publish examinable documents once a year should be made to the relevant Finance Act
to indicate exactly what regulations and article written by the examining team and
legislation could potentially be assessed published on the ACCA website.
within identified examination sessions.
None of the current or impending devolved
For most examinations (not tax), regulations taxes for Scotland, Wales, and Northern
issued or legislation passed on or before Ireland is, or will be, examinable.
31 August annually, will be examinable from
1 September of the following year to 31
August of the year after that. Please refer to
the examinable documents for the
examination (where relevant) for further
information.

Regulations issued or legislation passed in

accordance with the above dates will not be
examinable if the effective date is in the
future, unless explicitly stated otherwise in
the syllabus and study guide or examinable
documents.

The term issued or passed relates to when

regulation or legislation has been formally
approved.

The term effective relates to when regulation

or legislation must be applied to an entity
transactions and business practices.

The study guide offers more detailed

guidance on the depth and level at which the
examinable documents will be examined.
The study guide should therefore be read in
conjunction with the examinable documents
list.

For UK tax exams, examinations falling

within the period 1 June to 31 March will

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 Advanced Taxation – United Kingdom (ATX-UK)

6.Relational diagram linking Advanced Taxation – United

Kingdom (ATX-UK) with other exams

This diagram shows links between this exam and other exams preceding or following it.
Some exams are directly underpinned by other exams such as Advanced Taxation – United
Kingdom (ATX-UK) by Taxation – United Kingdom (TX-UK).

7. Approach to examining the syllabus

The exam consists of two sections:

Section A consists of two compulsory case-study questions. Question 1 has 35 marks,

including four professional marks and question 2 has 25 marks. There will also be five ethics
marks included within this section.

Section B consists of two compulsory 20-mark questions, covering both business and
personal tax issues.

Candidates will be expected to undertake both calculation and narrative work. The questions
will be scenario-based and may involve consideration of more than one tax, some elements
of planning and the interaction of taxes.

The examination is a three hour 15 minutes exam.

Tax rates, allowances and information on certain reliefs will be given in the exam.

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 Advanced Taxation – United Kingdom (ATX-UK)

8. Introduction to the syllabus

The aim of the syllabus is to apply relevant knowledge and skills and exercise professional
judgement in providing relevant information and advice to individuals and businesses on the
impact of the major taxes on financial decisions and situations.

The Advanced Taxation - United Kingdom (ATX-UK) syllabus further develops the key
aspects of taxation introduced in the compulsory Taxation – United Kingdom (TX-UK)
syllabus within the Applied Skills module and extends the candidates’ knowledge of the tax
system, together with their ability to apply that knowledge to the issues commonly
encountered by individuals and businesses, such that successful candidates should have
the ability to interpret and analyse the information provided and communicate the outcomes
in a manner appropriate to the intended audience.

The syllabus builds on the basic knowledge of core taxes from the earlier taxation exam and
introduces candidates to stamp taxes. As this is an optional exam, aimed at those
requiring/desiring more than basic tax knowledge for their future professional lives, the
syllabus also extends the knowledge of income tax, corporation tax, capital gains tax and
inheritance tax to encompass further overseas aspects of taxation, the taxation of trusts and
additional exemptions and reliefs.

Computations will normally only be required in support of explanations or advice and not in
isolation.

Candidates are not expected to concentrate on the computational aspects of taxation.

Instead this exam seeks to develop candidates’ skills of analysis, interpretation and
communication. Candidates are expected to be able to use established tax planning
methods and consider current issues in taxation.

Section E of the syllabus contains outcomes relating to the demonstration of appropriate

digital and employability skills in preparing for and taking the ATX-UK examination. This
includes being able to access and open exhibits, requirements and response options from
different sources and being able to use the relevant functionality and technology to prepare
and present response options in a professional manner. These skills are specifically
developed by practicing and preparing for the ATX-UK exam, using the learning support
content for computer-based exams available via the practice platform and the ACCA website
and will need to be demonstrated during the live exam.

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 Advanced Taxation – United Kingdom (ATX-UK)

9. Main capabilities

On successful completion of this exam, candidates should be able to:

A Apply further knowledge and understanding of the UK tax system through the study of
more advanced topics within the taxes studied previously and the study of stamp taxes

B Identify and evaluate the impact of relevant taxes on various situations and courses of
action, including the interaction of taxes

C Provide advice on minimising and/or deferring tax liabilities by the use of standard tax
planning measures

D Communicate with clients, HM Revenue and Customs and other professionals in an

appropriate manner.

E Apply employability and technology skills.

This diagram illustrates the flows and links between the main capabilities of the syllabus and
should be used as an aid to planning teaching and learning in a structured way.

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 Advanced Taxation – United Kingdom (ATX-UK)

3. Taxation effects of the financial

10. The syllabus decisions made by businesses
(corporate and unincorporated) and by
A Knowledge and understanding of the individuals.
UK tax system through the study of
more advanced topics within the 4. Tax advantages and/or disadvantages of
taxes studied previously and the alternative courses of action.
study of stamp taxes.
5. Statutory obligations imposed in a given
1. Income and income tax liabilities in situation, including any time limits for
situations involving further overseas action and the implications of non-
aspects and in relation to trusts, and the compliance.
application of additional exemptions and
reliefs. C Minimising and/or deferring tax
liabilities by the use of standard tax
2. Chargeable gains and capital gains tax planning measures
liabilities in situations involving further
overseas aspects and in relation to 1. Types of investment and other
closely related persons and trusts, and expenditure that will result in a reduction
the application of additional exemptions in tax liabilities for an individual and/or a
and reliefs. business.

3. Inheritance tax in situations involving 2. Legitimate tax planning measures, by

further aspects of the scope of the tax which the tax liabilities arising from a
and the calculation of the liabilities particular situation or course of action
arising, the principles of valuation and can be mitigated.
the reliefs available, transfers of property
to and from trusts, overseas aspects and 3. The appropriateness of such investment,
further aspects of administration. expenditure or measures, given a
particular taxpayer’s circumstances or
4. Corporation tax liabilities in situations stated objectives.
involving overseas and further group
aspects and in relation to special types 4. The mitigation of tax in the manner
of company, and the application of recommended, by reference to
additional exemptions and reliefs. numerical analysis and/or reasoned
argument.
5. Stamp taxes
5. Ethical and professional issues arising
6. Value added tax, tax administration and from the giving of tax planning advice.
the UK tax system
6. Current issues in taxation.
B The impact of relevant taxes on
various situations and courses of D Communicating with clients, HM
action, including the interaction of Revenue and Customs and other
taxes. professionals

1. Taxes applicable to a given situation or 1. Communication of advice,

course of action and their impact. recommendations and information in the
required format.
2. Alternative ways of achieving personal or
business outcomes may lead to different 2. Presentation of written information, in
tax consequences. language appropriate to the purpose of
the communication and the intended
recipient.

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 Advanced Taxation – United Kingdom (ATX-UK)

3. Conclusions reached with relevant

supporting computations.

4. Assumptions made or limitations in the

analysis provided, together with any
inadequacies in the information available
and/or additional information required to
provide a fuller analysis.

5. Other non-tax factors that should be

considered.

E Employability and technology skills

1. Use computer technology to efficiently
access and manipulate relevant
information.

2. Work on relevant response options,

using available functions and
technology, as would be required in the
workplace.

3. Navigate windows and computer

screens to create and amend responses
to exam requirements, using the
appropriate tools.

4. Present data and information effectively,

using the appropriate tools.

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 Advanced Taxation – United Kingdom (ATX-UK)

11. Detailed study guide v) Understand the relevance of the

OECD model double tax treaty to
given situations.
A Apply further knowledge and vi) Calculate and advise on the double
taxation relief available to individuals.
understanding of the UK tax
system through the study of c) Income from employment: [3]
more advanced topics within i) Advise on the tax treatment of
the taxes studied previously share option and share incentive
schemes.
and the study of stamp taxes ii) Advise on the tax treatment of
lump sum receipts.
1. Income and income tax liabilities in iii) Identify personal service
situations involving further overseas companies and advise on the tax
aspects and in relation to trusts, and consequences of providing
the application of exemptions and services via a personal service
reliefs. company.
a) The contents of the Taxation - United d) Income from self employment: [3]
Kingdom (TX-UK) study guide for i) Advise on a change of
income tax and national insurance, accounting date.
under headings:[2] ii) Advise on the relief available for
trading losses following the transfer
• B1 The scope of income tax of a business to a company.
• B2 Income from employment iii) Advise on the allocation of the
• B3 Income from self-employment annual investment allowance
• B4 Property and investment income between related businesses.
• B5 The comprehensive computation
of taxable income and the income tax e) Property and investment income: [3]
liability i) Advise on the tax implications of
• B6 National insurance contributions jointly held assets.
for employed and self-employed ii) Recognise the tax treatment of
persons savings income paid net of tax.
• B7 The use of exemptions and reliefs iii) Income from trusts and
in deferring and minimising income settlements: Understand the income
tax liabilities tax position of trust beneficiaries.

The following additional material is also f) The comprehensive computation of

examinable: taxable income and the income tax
liability:[3]
b) The scope of income tax: [3] i) Understand the allocation of the
i) Explain and apply the concepts personal allowance to different
of residence, domicile and deemed categories of income.
domicile and advise on the relevance ii) Advise on the income tax position of
to income tax. the income of minor children.
ii) Advise on the availability of the
remittance basis to UK resident g) The use of exemptions and reliefs in
individuals. deferring and minimising income tax
iii) Advise on the tax position of liabilities:
individuals coming to and leaving i) Understand and apply the rules
the UK. relating to investments in the seed
iv) Determine the income tax enterprise investment scheme and
treatment of overseas income. the enterprise investment scheme. [3]

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 Advanced Taxation – United Kingdom (ATX-UK)

ii) Understand and apply the rules The use of exemptions and reliefs in
relating to investments in venture deferring and minimising income tax
capital trusts. [3] liabilities:
iii) The threshold level of income below • The conditions that a company
which tapering of the pensions must meet in order to qualify as an
annual allowance does not apply.[2] EIS/SEIS/VCT company.
• The EIS as it applies to knowledge
Excluded topics intensive companies.
• The transfer of pension benefits on
The scope of income tax: death.
• Details of specific anti-avoidance
provisions, except as stated in the 2. Chargeable gains and capital gains
study guide. tax liabilities in situations involving
• Details of what consititutes a further overseas aspects and in
remittance. relation to closely related persons
• Profits of non-residents from a trade and trusts together with the
of dealing in or developing land in application of additional exemptions
the UK. and reliefs.
• Offshore receipts in respect of
intangible property. The contents of the Taxation - United
Kingdom (TX-UK) study guide for
Income from employment: chargeable gains for individuals under
• Explanation of the PAYE system. headings:[2]
• The overseas aspects of income • C1 The scope of the taxation of
from employment, including capital gains
travelling and subsistence • C2 The basic principles of
expenses. computing gains and losses
• C3 Gains and losses on the
Income from self employment: disposal of movable and immovable
• Details of specific anti-avoidance property
provisions, except as stated in the • C4 Gains and losses on the
study guide. disposal of shares and securities
• The tax treatment of overseas • C5 The computation of capital gains
travelling expenses. tax
• C6 The use of exemptions and
Property and investment income: reliefs in deferring and minimising
• Pre-owned assets tax liabilities arising on the disposal
• The accrued income scheme of capital assets
• The computation of income tax
payable by trustees. The following additional material is also
• Overseas aspects of income from examinable:
trusts and settlement.
b) The scope of the taxation of capital
The comprehensive computation of gains: [3]
taxable income and the income tax i) Determine the tax implications of
liability: independent taxation and
• The child benefit tax charge. transfers between spouses.
• Charitable donations. ii) Identify the concepts of
• Social security benefits apart from residence, domicile and deemed
the State Retirement Pension. domicile, and determine their
• The reduced anti-avoidance annual relevance to capital gains tax.
allowance applicable to taxpayers iii) Advise on the availability of the
accessing their pension flexibly. remittance basis to non-UK
domiciled individuals.

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 Advanced Taxation – United Kingdom (ATX-UK)

iv) Determine the UK taxation of the small part disposal rules

foreign gains, including double applicable to rights issues.
taxation relief. ii) Define a qualifying corporate bond
v) Conclude on the capital gains tax (QCB), and understand what makes
position of individuals coming to a corporate bond non-qualifying.
and leaving the UK. Understand the capital gains tax
vi) Advise on the UK taxation of gains implications of the disposal of QCBs
on the disposal of UK land and in exchange for cash or shares.
buildings owned by non-residents. iii) Apply the rules relating to
vii) Identify the occasions when a reorganisations, reconstructions
chargeable gain would arise on a and amalgamations and advise on
partner in a partnership on the the most tax efficient options
disposal of a partnership asset. available in given circumstances.
iv) Establish the relief for capital losses
c) Capital gains tax and trusts: on shares in unquoted trading
i) Advise on the capital gains tax companies.
implications of transfers of
property into trust. [3] g) The use of exemptions and reliefs in
ii) Advise on the capital gains tax deferring and minimising tax liabilities
implications of property passing arising on the disposal of capital assets:
[3]
absolutely from a trust to a
beneficiary.[2] i) Understand and apply enterprise
investment scheme reinvestment
d) The basic principles of computing gains relief.
and losses: [3] ii) Understand and apply seed
i) Identify connected persons for enterprise investment scheme
capital gains tax purposes and reinvestment relief.
advise on the tax implications of iii) Advise on the availability of business
transfers between connected asset disposal relief in relation to
persons. associated disposals.
ii) Advise on the impact of dates of iv) Understand and apply the relief
disposal. that is available on the transfer of
iii) Evaluate the use of capital losses an unincorporated business to a
in the year of death. limited company.
v) Understand the capital gains tax
e) Gains and losses on the disposal of implications of the variation of
movable and immovable property: [3] wills.
i) Extend the explanation of part
disposals to include small part Excluded topics
disposals of land.
ii) Determine the gain on the The scope of the taxation of capital
disposal of leases and wasting gains:
assets. • Detailed knowledge of the
iii) Extend the explanation of the statements of practice on
treatment of assets damaged, lost or partnership capital gains.
destroyed to include capital sums • Deemed disposals on a change in
received. the profit sharing ratio (PSR) of a
iv) Advise on the tax effect of making partnership.
negligible value claims. • Capital gains tax on disposals of
indirect interests in UK land and
f) Gains and losses on the disposal of buildings by non-residents.
shares and securities: [3]
i) Extend the explanation of the
treatment of rights issues to include

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 Advanced Taxation – United Kingdom (ATX-UK)

Capital gains tax and trusts: 3. Inheritance tax in situations involving

• Overseas aspects of capital gains further aspects of the scope of the tax
tax and trusts. and the calculation of the liabilities
• The computation of capital gains arising, the principles of valuation
tax payable by trustees. and the reliefs available, transfers of
• Transfers of property to or from property to and from trusts, overseas
trustees prior to 22 March 2006. aspects and further aspects of
• Knowledge of situations where administration.
property is transferred between
trusts or where the terms or nature a) The contents of the Taxation - United
of the trust is altered. Kingdom (TX-UK) study guide for
• Immediate post-death interest inheritance tax under headings:[2]
trusts. • D1 The basic principles of
• Knowledge of the special rules computing transfers of value
concerning trusts for the disabled, • D2 The liabilities arising on the
trusts for bereaved minors, chargeable lifetime transfers and on
transitional serial interest trusts and the death of an individual
age 18 to 25 trusts. • D3 The use of exemptions in
deferring and minimising
The basic principles of computing gains inheritance tax liabilities
and losses: • D4 Payment of inheritance tax
• Conditional contracts
• Rebasing of foreign assets held at 5 The following additional material is also
April 2017. examinable:

Gains and losses on the disposal of b) The scope of inheritance tax:

movable and immovable property: i) Explain the concepts of domicile
• The detailed calculations for and deemed domicile and
chattels where the cost or proceeds understand the application of
are less than £6,000, other than these concepts to inheritance
knowledge of the exemption where tax. [2]
both cost and proceeds are less ii) Identify excluded property. [2]
than £6,000. iii) Identify and advise on the tax
• Sets of chattels in relation to the implications of the location of
chattels exemption. assets. [3]
• The grant of a lease or sub-lease iv) Identify and advise on gifts with
out of either a freehold, long lease reservation of benefit. [3]
or short lease.
c) The basic principles of computing
• Appropriations to and from trading
transfers of value:
stock (inventory).
i) Advise on the principles of valuation
• Mixed use property.
including the related property rules.[3]
• Payment of capital gains tax by ii) Advise on the availability of
instalments (payments on account business property relief and
on disposals of residential property agricultural property relief.[3]
are examinable). iii) Identify exempt transfers.[2]
Gains and losses on the disposal of d) The liabilities arising on chargeable
shares and securities: lifetime transfers and on the death of an
• Computation of cost and indexed individual: [3]
cost within the s.104 TCGA 1992 i) Advise on the tax implications of
share pool. chargeable lifetime transfers.
ii) Advise on the tax implications of
transfers within seven years of death.

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 Advanced Taxation – United Kingdom (ATX-UK)

iii) Advise on the tax liability arising Excluded topics

on a death estate.
iv) Understand and apply the tapered The scope of inheritance tax:
withdrawal of the residence nil rate • Transfers of value by close
band where the net value of the companies.
estate exceeds £2 million.
v) Advise on the relief for the fall in The liabilities arising on chargeable
value of lifetime gifts. lifetime transfers and on the death of an
vi) Advise on the operation of quick individual:
succession relief. • Immediate post death interest trusts.
vii) Advise on the operation of double tax • Double grossing up on death.
relief for inheritance tax. • Relief on relevant business property
viii) Advise on the inheritance tax and agricultural property given as
effects and advantages of the exempt legacies.
variation of wills. • Detailed knowledge of the double
ix) Advise on the reduced rate of charges legislation.
inheritance tax payable when a
proportion of a person’s estate is The basic principles of computing
bequeathed to charity. transfers of value:
• Valuation of an annuity or an interest
e) The liabilities arising in respect of in possession where the trust interest
transfers to and from trusts and on is subject to an annuity.
property within trusts: • Woodlands relief.
i) Define a trust. [2]
• Conditional exemption for heritage
ii) Distinguish between different
property.
types of trust. [3]
iii) Advise on the inheritance tax
Inheritance tax and trusts:
implications of transfers of
• IHT aspects of discretionary trusts
property into trust. [3]
prior to 27 March 1974.
iv) Advise on the inheritance tax
implications of property passing • Trusts created prior to 22 March
absolutely from a trust to a 2006.
beneficiary. [2] • Computation of ten year charges and
v) Identify the occasions on which exit charges.
inheritance tax is payable by • Overseas aspects of inheritance tax
trustees. [3] and trusts.
• The conditions that had to be
f) The use of exemptions and reliefs in satisfied for a trust to be an
deferring and minimising inheritance tax accumulation and maintenance trust.
liabilities: [3] • Knowledge of situations where
i) Advise on the use of reliefs and property is transferred between trusts
exemptions to minimise or where the terms or nature of the
inheritance tax liabilities, as trust is altered.
mentioned in the sections above. • Knowledge of the special rules
concerning trusts for the disabled,
g) The system by which inheritance tax is trusts for bereaved minors,
administered, including the instalment transitional serial interest trusts and
option for the payment of tax: age 18 to 25 trusts.
i) Identify the occasions on which
inheritance tax may be paid by The system by which inheritance tax is
instalments.[2] administered,:
ii) Advise on the due dates, interest • Knowledge that instalment payments
and penalties for inheritance tax may carry interest and the criteria to
purposes.[3] be met for instalment payments to be
interest-bearing.

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 Advanced Taxation – United Kingdom (ATX-UK)

4. Corporation tax liabilities in situations determine the reliefs available by

involving further overseas and group reference to the size of the
aspects and in relation to special individual company/group.
types of company, and the application ii) Determine the tax treatment of
of additional exemptions and reliefs. non trading deficits on loan
relationships.
a) The contents of the Taxation - United iii) Recognise the alternative tax
Kingdom (TX-UK) study guide, for treatments of intangible assets
corporation tax, under headings:[2] and conclude on the best
• E1 The scope of corporation tax treatment for a given company.
• E2 Taxable total profits iv) Advise on the impact of the transfer
• E3 Chargeable gains for companies pricing and thin capitalisation rules
• E4 The comprehensive computation on companies.
of the corporation tax liability v) Advise on the restriction on the
• E5 The effect of a group corporate use of losses on a change in
structure for corporation tax ownership of a company.
purposes vi) Identify the restriction on carried
• E6 The use of exemptions and reliefs forward trading losses and capital
in deferring and minimising losses for companies with profits
corporation tax liabilities over £5 million.

The following additional material is also d) The comprehensive calculation of the

examinable: corporation tax liability: [3]
i) Assess the impact of the OECD
b) The scope of corporation tax: [3] model double tax treaty on
i) Identify and calculate corporation corporation tax.
tax for companies with ii) Evaluate the meaning and
investment business. implications of a permanent
ii) Close companies: establishment.
• Apply the definition of a close iii) Identify and advise on the tax
company to given situations implications of controlled foreign
companies.
• Conclude on the tax implications
iv) Advise on the tax position of
of a company being a close
overseas companies trading in
company or a close investment
the UK.
holding company
v) Calculate double taxation relief.
iii) Identify and evaluate the
significance of accounting periods on
e) The effect of a group structure for
administration or winding up.
corporation tax purposes: [3]
iv) Conclude on the tax treatment of
i) Advise on the allocation of the
returns to shareholders after winding
annual investment allowance
up has commenced.
between group or related
v) Advise on the tax implications of
companies.
a purchase by a company of its
ii) Advise on the tax consequences
own shares.
of a transfer of intangible assets.
vi) Identify personal service
iii) Advise on the tax consequences
companies and advise on the tax
of a transfer of a trade and assets
consequences of services being
where there is common control.
provided via a personal service
iv) Understand the meaning of
company.
consortium owned company and
consortium member.
c) Taxable total profits: [3]
v) Advise on the operation of
i) Identify qualifying research and
consortium relief.
development expenditure, both
vi) Determine pre-entry losses and
capital and revenue, and
understand their tax treatment.

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 Advanced Taxation – United Kingdom (ATX-UK)

vii) Determine the degrouping charge The comprehensive calculation of the

where a company leaves a group corporation tax liability:
within six years of receiving an asset • Corporation tax rates for companies
by way of a no gain/no loss transfer. in the process of winding up.
viii) Determine the effects of the anti- • Relief for overseas tax as an
avoidance provisions, where expense.
arrangements exist for a • Detailed knowledge of specific
company to leave a group. double taxation agreements.
ix) Advise on the tax treatment of an • Migration of a UK resident
overseas branch. company.
• Mixer companies.
f) The use of exemptions and reliefs in • Detailed computational questions
deferring and minimising corporation tax on the carry back and carry forward
liabilities: [3] of unrelieved foreign tax.
i) Determine the application of the • The reduction of double tax relief
substantial shareholdings where losses have been group
exemption. relieved.
• Offshore receipts in respect of
Excluded topics
intangible property.
• Restrictions on the repayment of
The scope of corporation tax:
losses incurred by small and
• Details of specific anti-avoidance
medium sized enterprises (SMEs)
provisions, except as stated in the
arising from research and
Study Guide.
development expenditure
• Profits of non-residents from a trade
of dealing in or developing land in The effect of a group structure for
the UK. corporation tax purposes:
• Responsibility of senior accounting • The relief for trading losses incurred
officers (SAOs) in relation to by an overseas subsidiary
accounting systems
The use of exemptions and reliefs in
Taxable total profits: deferring and minimising corporation tax
• Profits attributable to patents liabilities:
• Pre-2002 intangible fixed assets • The substantial shareholdings
• Tax avoidance involving carry exemption as it applies to
forward losses institutional investors.
• Restriction of the deduction of
interest expenses for groups with a 5. Stamp taxes (stamp duty, stamp duty
net interest expense of £2 million reserve tax, and stamp duty land tax).
• Diverted profits tax
• The disposal of investments in UK a) The scope of stamp taxes: [3]
land and buildings by non-resident i) Identify the property in respect of
companies. which stamp taxes are
• Chargeable gains on disposals of payable.
indirect interests in UK land and
buildings by non-resident b) Identify and advise on the liabilities
companies arising on transfers. [3]
• Tax relief available in respect of i) Advise on the stamp taxes payable
goodwill and customer related on transfers of shares and securities.
intangibles on a business ii) Advise on the stamp taxes payable
acquisition where qualifying on transfers of land.
intellectual property is also
acquired. c) The use of exemptions and reliefs in
deferring and minimising stamp taxes: [3]

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 Advanced Taxation – United Kingdom (ATX-UK)

i) Identify transfers involving no and payment of tax, including

consideration. payments on account
ii) Advise on group transactions. • A5 The procedures relating to
compliance checks, appeals and
Excluded topics disputes
• A6 Penalties for non-compliance
The scope of stamp taxes:
• Leases The following additional material is also
• Land and Buildings Transaction Tax examinable: [2]
(LBTT)
i) Advise on the increased
The liabilities arising on transfers: penalties which apply in relation
• The contingency principle. to offshore matters.
• Residential property
• The systems by which stamp taxes Excluded topics
are administered
Value added tax:
6. Value added tax, tax administration • The determination of the tax point.
and the UK tax system: • The contents of a valid VAT invoice.
• Special place of supply rules for
a) The contents of the Taxation - United business to consumer supplies of
Kingdom (TX-UK) study guide for value telecommunications, broadcasting
added tax (VAT) under headings: [2] and e-services.
• F1 The VAT registration • Disaggregation of business activities
requirements for VAT purposes.
• F2 The computation of VAT • Divisional registration
liabilities • Making tax digital
• F3 The effect of special schemes
The UK tax system and its
The following additional material is also Administration:
examinable:[3] • Extension of offshore assessment
time limits.
i) Advise on the VAT implications
of the supply of land and B The impact of relevant taxes
buildings in the UK.
ii) Advise on the VAT implications
on various situations and
of partial exemption. courses of action, including
iii) Advise on the application of the the interaction of taxes
capital goods scheme.
1. Identify and advise on the taxes
b) The contents of the Taxation - United applicable to a given course of action
Kingdom (TX-UK) study guide for the UK and their impact.[3]
tax system and its administration under
headings: [2] 2. Identify and understand that the
• A1 The overall function and alternative ways of achieving
purpose of taxation in a modern personal or business outcomes may
economy lead to different tax consequences.
• A2 Principal sources of revenue law
and practice a) Calculate the receipts from a transaction,
• A3 The systems for self net of tax and compare the results of
assessment and the making of alternative scenarios and advise on the
returns most tax efficient course of action.[3]
• A4 The time limits for the
submission of information, claims

20 © ACCA 2022-2023 All rights reserved.

 Advanced Taxation – United Kingdom (ATX-UK)

3. Advise how taxation can affect the 4. Advise on the mitigation of tax in the
financial decisions made by manner recommended by reference to
businesses (corporate and numerical analysis and/or reasoned
unincorporated) and by individuals. argument.[3]

a) Understand and compare and contrast 5. Be aware of the ethical and

the tax treatment of the sources of professional issues arising from the
finance and investment products giving of tax planning advice.[3]
available to individuals.[3]
6. Be aware of and give advice on
b) Understand and explain the tax current issues in taxation.[3]
implications of the raising of equity
and loan finance.[3] D Communicate with clients,
c) Explain the tax differences between
HM Revenue and Customs
decisions to lease, use hire and other professionals in an
purchase or purchase outright.[3] appropriate manner
d) Understand and explain the impact 1. Communicate advice,
of taxation on the cash flows of a recommendations and information in
business.[3] the required format:[3]

4. Assess the tax advantages and For example the use of:
disadvantages of alternative • Reports
courses of action.[3] • Letters
• Memoranda
5. Understand the statutory • Meeting notes
obligations imposed in a given
situation, including any time 2. Present written information, in
limits for action and advise on the language appropriate to the purpose
implications of non-compliance.[3] of the communication and the
intended recipient.[3]
C Minimise and/or defer tax
liabilities by the use of 3. Communicate conclusions reached,
together, where necessary with
standard tax planning relevant supporting computations.[3]
measures
4. State and explain assumptions made
1. Identify and advise on the types of or limitations in the analysis
investment and other expenditure that provided; together with any
will result in a reduction in tax inadequacies in the information
liabilities for an individual and/or a available and/or additional
business.[3] information required to provide a
fuller analysis.[3]
2. Advise on legitimate tax planning
measures, by which the tax liabilities 5. Identify and explain other, non-tax,
arising from a particular situation or factors that should be considered.[3]
course of action can be mitigated.[3]

3. Advise on the appropriateness of

such investment, expenditure or
measures given a particular
taxpayer’s circumstances or stated
objectives.[3]

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 Advanced Taxation – United Kingdom (ATX-UK)

E Employability and technology

skills
1. Use computer technology to
efficiently access and manipulate
relevant information

2. Work on relevant response options,

using available functions and
technology, as would be required in
the workplace

3. Navigate windows and computer

screens to create and amend
responses to exam requirements,
using the appropriate tools

4. Present data and information

effectively, using the appropriate
tools

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 Advanced Taxation – United Kingdom (ATX-UK)

12.Summary of changes to Advanced Taxation (ATX-UK)

ACCA periodically reviews its qualification syllabuses so that they fully meet the needs of
stakeholders such as employers, students, regulatory and advisory bodies and learning
providers.

There are changes to the syllabus and these are summarised in the tables below.

Table 1 – Additions

Section and subject area Syllabus content and rationale

A4c Taxable total profits – New exclusion added:

Excluded topics Restrictions on the repayment of
losses incurred by small and
medium sized enterprises (SMEs)
arising from research and
development expenditure

E1 – E4 Employability and To reflect the outcomes and

technology skills section demonstrable skills required for the
added ATX-UK examination, using the
available technology.

There have been no other amendents to the syllabus

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