Advanced Taxation - United Kingdom (ATX-UK) : Syllabus and Study Guide

Advanced Taxation – United Kingdom (ATX-UK)
Advanced
Taxation –
United Kingdom
(ATX-UK)
Syllabus and study guide
June 2020 to March 2021
© ACCA 2020-2021 All rights reserved.

Summary of content
Introduction
1. Intellectual levels
2. Learning hours and educational
recognition
3. Guide to ACCA examination structure
4. Guide to ACCA examination
assessment
Advanced Taxation – United
Kingdom syllabus
5. Relational diagram linking Advanced
Taxation – United Kingdom with other
exams
6. Overall aim of the syllabus
7. Main capabilities
8. Rationale
9. Approach to examining the syllabus
10. The syllabus
Advanced Taxation – United
Kingdom study guide
11. Detailed study guide

1. Intellectual levels 2. Learning hours and

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

3. Guide to ACCA Strategic Professional

Strategic Business Leader is ACCA’s
examination structure case study examination at Strategic
The structure and delivery mode of Professional and is examined as a
examinations varies. closed book exam of four hours,
including reading, planning and
Applied Knowledge reflection time which can be used
The Applied Knowledge examinations flexibly within the examination. There is
contain 100% compulsory questions to no pre-seen information and all exam
encourage candidates to study across related material, including case
the breadth of each syllabus. These information and exhibits are available
are assessed by a two-hour computer within the examination. Strategic
based examination. Business Leader is an exam based on
one main business scenario which
Applied Skills involves candidates completing several
The Corporate and Business Law exam tasks within which additional material
is a two-hour computer-based objective may be introduced. All questions are
test examination for English and Global. compulsory and each examination will
For the format and structure of the contain a total of 80 technical marks and
Corporate and Business Law or 20 Professional Skills marks.
Taxation variant exams, refer to the
‘Approach to examining the syllabus’ in The other Strategic Professional exams
section 9 of the relevant syllabus and are all of three hours and 15 minutes
study guide. duration. All contain two
Sections and all questions are
The other Applied Skills examinations compulsory. These exams all contain
(PM, TX-UK, FR, AA, and FM) four professional marks.
contain a mix of objective and longer
type questions with a duration of three For September and December 2019
hours for 100 marks. These are sessions, all Strategic Professional
assessed by a three hour computer- exams will be assessed by paper based
based exam. Prior to the start of each examination. From March 2020, these
exam there will be time allocated for exams will become available by
students to be informed of the exam computer based examination. More
instructions. detail regarding what is available in your
market will be on the ACCA global
The longer (constructed response) website.
question types used in the Applied Skills
exams (excluding Corporate and With Applied Knowledge and Applied
Business Law) require students to Skills exams now assessed by computer
effectively mimic what they do in the based exam, ACCA is committed to
workplace. Students will need to use a continuing on its journey to assess all
range of digital skills and demonstrate exams within the ACCA Qualification
their ability to use spreadsheets and using this delivery mode.
word processing tools in producing their
answers, just as they would use these The question types used at Strategic
tools in the workplace. These Professional again require students to
assessment methods allow ACCA to effectively mimic what they would do in
focus on testing students’ technical and the workplace and, with the move to
application skills, rather than, for CBE, these exams again offer ACCA the
example, their ability to perform simple opportunity to focus on the application of
calculations. knowledge to scenarios, using a range
of tools – spreadsheets, word
processing and presentations - not only

enabling students to demonstrate their

technical and professional skills but also
their use of the technology available to
today’s accountants.
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.
The pass mark for all ACCA

Qualification examinations is 50%.

4. Guide to ACCA For UK tax exams, examinations falling

within the period 1 June to 31 March will
examination generally examine the Finance Act
assessment which was passed in the previous year.
Therefore, exams falling in the period 1
ACCA reserves the right to examine any June 2020 to 31 March 2021 will
learning outcome contained within the examine the Finance Act 2019 and any
study guide. This includes knowledge, examinable legislation which is passed
techniques, principles, theories, and outside of the Finance Act before 31
concepts as specified. For the financial May 2019.
accounting, audit and assurance, law
and tax exams except where indicated In addition, for exams in the period 1
otherwise, ACCA will publish June 2020 to 31 March 2021, all
examinable documents once a year to questions will assume that the UK
indicate exactly what regulations and remains in the European Union.
legislation could potentially be assessed
For additional guidance on the
within identified examination sessions.
examinability of specific tax rules and
the depth in which they are likely to be
For most examinations (not tax),
examined, reference should be made to
regulations issued or legislation passed
the relevant Finance Act article written
on or before 31 August annually, will be by the examining team and published on
examinable from 1 September of the the ACCA website.
following year to 31 August of the year
after that. Please refer to the None of the current or impending
examinable documents for the devolved taxes for Scotland, Wales, and
examination (where relevant) for further Northern Ireland is, or will be,
information. examinable.
Regulations issued or legislation passed

in accordance with the above dates may
be examinable even if the effective date
is in the future.
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.

5. 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).
This diagram indicates where students are expected to have underpinning

knowledge and where it would be useful to review previous learning before
undertaking study.
6. Overall aim of the syllabus
This syllabus and study guide is designed to help with planning study and to provide
detailed information on what could be assessed in any examination session.
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.

7. 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.
Relational diagram of the main capabilities
This diagram illustrates the flows and links between the main capabilities (sections)
of the syllabus and should be used as an aid to planning teaching and learning in a
structured way.

8. Rationale
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.

9. 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.

10. The syllabus

A Knowledge and understanding of 1. Taxes applicable to a given situation
the UK tax system through the or course of action and their impact.
study of more advanced topics
within the taxes studied 2. Alternative ways of achieving
previously and the study of stamp personal or business outcomes may
taxes. lead to different tax consequences.
1. Income and income tax liabilities in 3. Taxation effects of the financial

situations involving further overseas decisions made by businesses
aspects and in relation to trusts, and (corporate and unincorporated) and
the application of additional by individuals.
exemptions and reliefs.
4. Tax advantages and/or
2. Chargeable gains and capital gains disadvantages of alternative
tax liabilities in situations involving courses of action.
further overseas aspects and in
relation to closely related persons 5. Statutory obligations imposed in a
and trusts, and the application of given situation, including any time
additional exemptions and reliefs. limits for action and the implications
of non-compliance.
3. Inheritance tax in situations involving
further aspects of the scope of the C Minimising and/or deferring tax
tax and the calculation of the liabilities by the use of standard
liabilities arising, the principles of tax planning measures
valuation and the reliefs available,
transfers of property to and from 1. Types of investment and other
trusts, overseas aspects and further expenditure that will result in a
aspects of administration. reduction in tax liabilities for an
individual and/or a business.
4. Corporation tax liabilities in
situations involving overseas and 2. Legitimate tax planning measures,
further group aspects and in relation by which the tax liabilities arising
to special types of company, and the from a particular situation or course
application of additional exemptions of action can be mitigated.
and reliefs.
3. The appropriateness of such
5. Stamp taxes investment, expenditure or
measures, given a particular
6. Value added tax, tax administration taxpayer’s circumstances or stated
and the UK tax system objectives.
B The impact of relevant taxes on 4. The mitigation of tax in the manner

various situations and courses of recommended, by reference to
action, including the interaction of numerical analysis and/or reasoned
taxes. argument.

5. Ethical and professional issues

arising from the giving of tax
planning advice.
6. Current issues in taxation.
D Communicating with clients, HM

Revenue and Customs and other
professionals
1. Communication of advice,
recommendations and information in
the required format.
2. Presentation of written information,

in language appropriate to the
purpose of the communication and
the intended recipient.
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.

11. Detailed study guide ii) Advise on the availability of the

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

f) The comprehensive computation of Income from self employment:

taxable income and the income tax • Details of specific anti-
liability:[3] avoidance provisions, except
i) Understand the allocation of the as stated in the study guide.
personal allowance to different • The tax treatment of overseas
categories of income. travelling expenses.
ii) Advise on the income tax
position of the income of minor Property and investment income:
children. • Pre-owned assets
• The accrued income scheme
g) The use of exemptions and reliefs in • The computation of income tax
deferring and minimising income tax payable by trustees.
liabilities: • Overseas aspects of income
i) Understand and apply the rules from trusts and settlement.
relating to investments in the
seed enterprise investment The comprehensive computation of
scheme and the enterprise taxable income and the income tax
investment scheme. [3] liability:
ii) Understand and apply the rules • The child benefit tax charge.
relating to investments in
• Charitable donations.
venture capital trusts. [3]
• Social security benefits apart
iii) The threshold level of income
from the State Retirement
below which tapering of the
Pension.
pensions annual allowance does
not apply.[2] • The £10,000 anti-avoidance
annual allowance applicable to
Excluded topics taxpayers accessing their
pension flexibly.
The scope of income tax:
The use of exemptions and reliefs in
• Details of specific anti-
deferring and minimising income tax
avoidance provisions, except
liabilities:
as stated in the study guide.
• The conditions that a company
• Details of what consititutes a
must meet in order to qualify as
remittance.
an EIS/SEIS/VCT company.
• Profits of non-residents from a
• The EIS as it applies to
trade of dealing in or
knowledge intensive
developing land in the UK.
companies.
• Offshore receipts in respect of
• The transfer of pension benefits
intangible property.
on death.
Income from employment:
• Explanation of the PAYE
system.
• The overseas aspects of
income from employment,
including travelling and
subsistence expenses.

2. Chargeable gains and capital v) Conclude on the capital gains tax

gains tax liabilities in situations position of individuals coming to
involving further overseas and leaving the UK.
aspects and in relation to closely vi) Advise on the UK taxation of
related persons and trusts gains on the disposal of UK
together with the application of land and buildings owned by
additional exemptions and reliefs. non-residents.
vii) Identify the occasions when a
The contents of the Taxation - capital gain would arise on a
United Kingdom (TX-UK) study partner in a partnership on the
guide for chargeable gains for disposal of a partnership asset.
individuals under headings:[2]
• C1 The scope of the taxation of c) Capital gains tax and trusts:
capital gains i) Advise on the capital gains tax
• C2 The basic principles of implications of transfers of
computing gains and losses property into trust. [3]
• C3 Gains and losses on the ii) Advise on the capital gains tax
disposal of movable and implications of property passing
immovable property absolutely from a trust to a
• C4 Gains and losses on the beneficiary.[2]
disposal of shares and
securities d) The basic principles of computing
• C5 The computation of capital gains and losses: [3]
gains tax i) Identify connected persons for
• C6 The use of exemptions and capital gains tax purposes and
reliefs in deferring and advise on the tax implications of
minimising tax liabilities arising transfers between connected
on the disposal of capital persons.
assets ii) Advise on the impact of dates of
disposal.
The following additional material is iii) Evaluate the use of capital losses
also examinable: in the year of death.
b) The scope of the taxation of capital e) Gains and losses on the disposal of
gains: [3] movable and immovable property: [3]
i) Determine the tax implications of i) Extend the explanation of part
independent taxation and disposals to include small part
transfers between spouses. disposals of land.
ii) Identify the concepts of ii) Determine the gain on the
residence, domicile and deemed disposal of leases and
domicile, and determine their wasting assets.
relevance to capital gains tax. iii) Extend the explanation of the
iii) Advise on the availability of the treatment of assets damaged,
remittance basis to non-UK lost or destroyed to include
domiciled individuals. capital sums received.
iv) Determine the UK taxation of iv) Advise on the tax effect of
foreign gains, including making negligible value
double taxation relief. claims.

f) Gains and losses on the disposal of Excluded topics

shares and securities: [3]
i) Extend the explanation of the The scope of the taxation of capital
treatment of rights issues to gains:
include the small part disposal • Detailed knowledge of the
rules applicable to rights issues. statements of practice on
ii) Define a qualifying corporate partnership capital gains.
bond (QCB), and understand • Deemed disposals on a change
what makes a corporate bond in the profit sharing ratio (PSR)
non-qualifying. Understand the of a partnership.
capital gains tax implications of • CGT on disposals of indirect
the disposal of QCBs in interests in UK land and
exchange for cash or shares. buildings by non-residents.
iii) Apply the rules relating to
reorganisations, reconstructions Capital gains tax and trusts:
and amalgamations and • Overseas aspects of capital
advise on the most tax efficient gains tax and trusts.
options available in given • The computation of capital
circumstances . gains tax payable by trustees.
iv) Establish the relief for capital • Transfers of property to or from
losses on shares in unquoted trustees prior to 22 March
trading companies. 2006.
• Knowledge of situations where
g) The use of exemptions and reliefs in property is transferred between
deferring and minimising tax trusts or where the terms or
liabilities arising on the disposal of nature of the trust is altered.
capital assets: [3]
• Immediate post-death interest
i) Understand and apply enterprise
trusts.
investment scheme reinvestment
• Knowledge of the special rules
relief.
concerning trusts for the
ii) Understand and apply seed
disabled, trusts for bereaved
enterprise investment scheme
minors, transitional serial
reinvestment relief.
interest trusts and age 18 to 25
iii) Advise on the availability of
trusts.
entrepreneurs’ relief in relation to
associated disposals.
The basic principles of computing
iv) Understand and apply the relief
gains and losses:
that is available on the transfer of
an unincorporated business to a • Conditional contracts
limited company. • Rebasing of foreign assets held
v) Understand the capital gains tax at 5 April 2017.
implications of the variation of
wills. Gains and losses on the disposal of
movable and immovable property:
• The detailed calculations for
chattels where the cost or
proceeds are less than £6,000,
other than knowledge of the
exemption where both cost and
proceeds are less than £6,000.

• Sets of chattels in relation to these concepts to inheritance

the chattels exemption. tax. [2]
• The grant of a lease or sub- ii) Identify excluded property. [2]
lease out of either a freehold, iii) Identify and advise on the tax
long lease or short lease. implications of the location of
• Appropriations to and from assets. [3]
trading stock (inventory). iv) Identify and advise on gifts with
• Mixed use property. reservation of benefit. [3]
• Payment of capital gains tax by
instalments. c) The basic principles of computing
transfers of value:
Gains and losses on the disposal of i) Advise on the principles of
shares and securities: valuation including the related
• Computation of cost and property rules.[3]
indexed cost within the s.104 ii) Advise on the availability of
TCGA 1992 share pool. business property relief and
agricultural property relief.[3]
3. Inheritance tax in situations iii) Identify exempt transfers.[2]
involving further aspects of the
scope of the tax and the d) The liabilities arising on chargeable
calculation of the liabilities lifetime transfers and on the death of
arising, the principles of valuation an individual: [3]
and the reliefs available, transfers i) Advise on the tax implications of
of property to and from trusts, chargeable lifetime transfers.
overseas aspects and further ii) Advise on the tax implications of
aspects of administration. transfers within seven
years of death.
a) The contents of the Taxation - iii) Advise on the tax liability arising
United Kingdom (TX-UK) study on a death estate.
guide for inheritance tax under iv) Advise on the relief for the fall in
headings:[2] value of lifetime gifts.
• D1 The basic principles of v) Advise on the operation of quick
computing transfers of value succession relief.
vi) Advise on the operation of
• D2 The liabilities arising on the
double tax relief for inheritance
chargeable lifetime transfers
tax.
and on the death of an
vii) Advise on the inheritance tax
individual
effects and advantages of the
• D3 The use of exemptions in
variation of wills.
deferring and minimising
viii)Advise on the reduced rate of
inheritance tax liabilities
inheritance tax payable when a
• D4 Payment of inheritance tax proportion of a person’s estate is
bequeathed to charity.
The following additional material is
also examinable: e) The liabilities arising in respect of
transfers to and from trusts and on
b) The scope of inheritance tax: property within trusts:
i) Explain the concepts of domicile i) Define a trust. [2]
and deemed domicile and
understand the application of

ii) Distinguish between different The basic principles of computing

types of trust. [3] transfers of value:
iii) Advise on the inheritance tax • Valuation of an annuity or an
implications of transfers of interest in possession where the
property into trust. [3] trust interest is subject to an
iv) Advise on the inheritance tax annuity.
implications of property passing • Woodlands relief.
absolutely from a trust to a • Conditional exemption for
beneficiary. [2] heritage property.
v) Identify the occasions on which
inheritance tax is payable by Inheritance tax and trusts:
trustees. [3] • IHT aspects of discretionary
trusts prior to 27 March 1974.
f) The use of exemptions and reliefs in • Trusts created prior to 22 March
deferring and minimising inheritance 2006.
tax liabilities: [3] • Computation of ten year charges
i) Advise on the use of reliefs and and exit charges.
exemptions to minimise • Overseas aspects of inheritance
inheritance tax liabilities, as tax and trusts.
mentioned in the sections above.
• The conditions that had to be
satisfied for a trust to be an
g) The system by which inheritance tax
accumulation and maintenance
is administered, including the
trust.
instalment option for the payment of
• Knowledge of situations where
tax:
property is transferred between
i) Identify the occasions on which
trusts or where the terms or
inheritance tax may be paid by
nature of the trust is altered.
instalments.[2]
ii) Advise on the due dates, interest • Knowledge of the special rules
and penalties for inheritance tax concerning trusts for the
purposes.[3] disabled, trusts for bereaved
minors, transitional serial interest
Excluded topics trusts and age 18 to 25 trusts.
The scope of inheritance tax: The system by which inheritance tax

is administered,:
• Transfers of value by close
companies. • Knowledge that instalment
payments may carry interest and
The liabilities arising on chargeable the criteria to be met for
lifetime transfers and on the death of instalment payments to be
an individual: interest-bearing.
• Immediate post death interest
4. Corporation tax liabilities in
trusts.
situations involving further
• Double grossing up on death.
overseas and group aspects and
• Relief on relevant business in relation to special types of
property and agricultural property company, and the application of
given as exempt legacies. additional exemptions and reliefs.
• Detailed knowledge of the
double charges legislation.

a) The contents of the Taxation - provided via a personal service

United Kingdom (TX-UK) study company.
guide, for corporation tax, under
headings:[2] c) Taxable total profits: [3]
• E1 The scope of corporation tax i) Identify qualifying research and
• E2 Taxable total profits development expenditure, both
• E3 Chargeable gains for capital and revenue, and
companies determine the reliefs available by
• E4 The comprehensive reference to the size of the
computation of the corporation individual company/group.
tax liability ii) Determine the tax treatment of
• E5 The effect of a group non trading deficits on loan
corporate structure for relationships.
corporation tax purposes iii) Recognise the alternative tax
• E6 The use of exemptions and treatments of intangible assets
reliefs in deferring and and conclude on the best
minimising corporation tax treatment for a given company.
liabilities iv) Advise on the impact of the
transfer pricing and thin
The following additional material is capitalisation rules on
also examinable: companies.
v) Advise on the restriction on the
b) The scope of corporation tax: [3] use of losses on a change in
i) Identify and calculate corporation ownership of a company.
tax for companies with
investment business. d) The comprehensive calculation of
ii) Close companies: the corporation tax liability: [3]
• Apply the definition of a i) Assess the impact of the OECD
close company to given model double tax treaty on
situations corporation tax.
ii) Evaluate the meaning and
• Conclude on the tax
implications of a permanent
implications of a company
establishment.
being a close company or a
iii) Identify and advise on the tax
close investment holding
implications of controlled
company
foreign companies.
iii) Identify and evaluate the
iv) Advise on the tax position of
significance of accounting
overseas companies trading in
periods on administration or
the UK.
winding up.
v) Calculate double taxation relief.
iv) Conclude on the tax treatment of
returns to shareholders after
e) The effect of a group structure for
winding up has commenced.
corporation tax purposes: [3]
v) Advise on the tax implications of
i) Advise on the allocation of the
a purchase by a company of its
annual investment allowance
own shares.
between group or related
vi) Identify personal service
companies.
companies and advise on the tax
consequences of services being

ii) Advise on the tax consequences Taxable total profits:

of a transfer of intangible • Profits attributable to patents
assets. • Carried forward losses which
iii) Advise on the tax consequences arose in accounting periods
of a transfer of a trade and which straddle 1 April 2017
assets where there is common • Tax avoidance involving carry
control. forward losses
iv) Understand the meaning of • Restriction of the deduction of
consortium owned company and interest expenses for groups
consortium member. with a net interest expense of
v) Advise on the operation of £2 million
consortium relief. • Diverted profits tax
vi) Determine pre-entry losses and • The disposal of investments in
understand their tax treatment. UK land and buildings by non-
vii) Determine the degrouping resident companies.
charge where a company leaves • CGT on disposals of indirect
a group within six years of interests in UK land and
receiving an asset by way of a buildings by non-resident
no gain/no loss transfer. companies
viii) Determine the effects of the anti-
• Tax relief available in respect of
avoidance provisions, where
goodwill and customer related
arrangements exist for a
intangibles on a business
company to leave a group.
acquisition where qualifying
ix) Advise on the tax treatment of an
intellectual property is also
overseas branch.
acquired.
f) The use of exemptions and reliefs in
The comprehensive calculation of
deferring and minimising corporation
the corporation tax liability:
tax liabilities: [3]
• Corporation tax rates for
i) Determine the application of the
companies in the process of
substantial shareholdings
winding up.
exemption.
• Relief for overseas tax as an
Excluded topics expense.
• Detailed knowledge of specific
The scope of corporation tax: double taxation agreements.
• Details of specific anti- • Migration of a UK resident
avoidance provisions, except company.
as stated in the Study Guide. • Mixer companies.
• Profits of non-residents from a • Detailed computational
trade of dealing in or questions on the carry back
developing land in the UK. and carry forward of unrelieved
• Responsibility of senior foreign tax.
accounting officers (SAOs) in • The reduction of double tax
relation to accounting systems relief where losses have been
group relieved.
• Offshore receipts in respect of
intangible property.

The effect of a group structure for 6. Value added tax, tax

corporation tax purposes: administration and the UK tax
• The relief for trading losses system:
incurred by an overseas
subsidiary a) The contents of the Taxation -
United Kingdom (TX-UK) study
The use of exemptions and reliefs in guide for value added tax (VAT)
deferring and minimising under headings: [2]
corporation tax liabilities: • F1 The VAT registration
• The substantial shareholdings requirements
exemption as it applies to • F2 The computation of VAT
institutional investors. liabilities
• F3 The effect of special
5. Stamp taxes (stamp duty, stamp schemes
duty reserve tax, and stamp duty
land tax). The following additional material is
also examinable:[3]
a) The scope of stamp taxes: [3]
i) Identify the property in respect of i) Advise on the VAT implications
which stamp taxes are of the supply of land and
payable. buildings in the UK.
ii) Advise on the VAT implications
b) Identify and advise on the liabilities of partial exemption.
arising on transfers. [3] iii) Advise on the application of the
i) Advise on the stamp taxes capital goods scheme.
payable on transfers of shares
and securities. b) The contents of the Taxation -
ii) Advise on the stamp taxes United Kingdom (TX-UK) study
payable on transfers of land. guide for the UK tax system and its
administration under headings: [2]
c) The use of exemptions and reliefs in • A1 The overall function and
deferring and minimising stamp purpose of taxation in a modern
taxes: [3] economy
i) Identify transfers involving no • A2 Principal sources of revenue
consideration. law and practice
ii) Advise on group transactions. • A3 The systems for self
assessment and the making of
Excluded topics returns
• A4 The time limits for the
The scope of stamp taxes: submission of information,
• Leases claims and payment of tax,
• Land and Buildings Transaction including payments on account
Tax (LBTT) • A5 The procedures relating to
compliance checks, appeals
The liabilities arising on transfers: and disputes
• The contingency principle. • A6 Penalties for non-
• Residential property compliance
• The systems by which stamp
taxes are administered

The following additional material is also and advise on the most tax efficient
examinable: [3] course of action.[3]
i) Advise on the increased 3. Advise how taxation can affect

penalties which apply in relation the financial decisions made by
to offshore matters. [2] businesses (corporate and
unincorporated) and by
Excluded topics individuals.
Value added tax: a) Understand and compare and

• The determination of the tax contrast the tax treatment of the
point. sources of finance and investment
• The contents of a valid VAT products available to individuals.[3]
invoice.
• Special place of supply rules for b) Understand and explain the tax
business to consumer supplies implications of the raising of equity
of telecommunications, and loan finance.[3]
broadcasting and e-services.
• Disaggregation of business c) Explain the tax differences between
activities for VAT purposes. decisions to lease, use hire
• Divisional registration purchase or purchase outright.[3]
• Making tax digital
d) Understand and explain the impact
The UK tax system and its of taxation on the cash flows of a
Administration: business.[3]
• Extension of offshore
assessment time limits. 4. Assess the tax advantages and
disadvantages of alternative
courses of action.[3]
B The impact of relevant
taxes on various 5. Understand the statutory
situations and courses of obligations imposed in a given
situation, including any time
action, including the limits for action and advise on the
interaction of taxes implications of non-compliance.[3]
1. Identify and advise on the taxes

applicable to a given course of
C Minimise and/or defer tax
action and their impact.[3] liabilities by the use of
standard tax planning
2. Identify and understand that the measures
alternative ways of achieving
personal or business outcomes 1. Identify and advise on the types
may lead to different tax of investment and other
consequences. expenditure that will result in a
reduction in tax liabilities for an
a) Calculate the receipts from a individual and/or a business.[3]
transaction, net of tax and compare
the results of alternative scenarios

2. Advise on legitimate tax planning necessary with relevant

measures, by which the tax supporting computations.[3]
liabilities arising from a particular
situation or course of action can 4. State and explain assumptions
be mitigated.[3] made or limitations in the analysis
provided; together with any
3. Advise on the appropriateness of inadequacies in the information
such investment, expenditure or available and/or additional
measures given a particular information required to provide a
taxpayer’s circumstances or fuller analysis.[3]
stated objectives.[3]
5. Identify and explain other, non-
4. Advise on the mitigation of tax in tax, factors that should be
the manner recommended by considered.[3]
reference to numerical analysis
and/or reasoned argument.[3]
5. Be aware of the ethical and

professional issues arising from
the giving of tax planning
advice.[3]
6. Be aware of and give advice on

current issues in taxation.[3]
D Communicate with clients,

HM Revenue and Customs
and other professionals in
an appropriate manner
1. Communicate advice,
recommendations and
information in the required
format:[3]
For example the use of:

• Reports
• Letters
• Memoranda
• Meeting notes
2. Present written information, in

language appropriate to the
purpose of the communication
and the intended recipient.[3]
3. Communicate conclusions
reached, together, where

Summary of changes to Advanced Taxation - United

Kingdom (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
A1b) The scope of income tax – New excluded topic added:

Excluded topics • Offshore receipts in respect
of intangible property
A2b) The scope of the taxation of New excluded topic added:
capital gains – Excluded • CGT on disposals of indirect
topics interests in UK land and
buildings by non-residents
A4c) Taxable total profits – New excluded topics added:
Excluded topics • The disposal of investments
in UK land and buildings by
non-resident companies
• CGT on disposals of indirect
interests in UK land and
buildings by non-resident
companies
• Tax relief available in respect
of goodwill and customer
related intangibles on a
business acquisition where
qualifying intellectual
property is also acquired
A4d) The comprehensive calculation New excluded topics added:
of the corporation tax liability – • Offshore receipts in respect of
Excluded topics intangible property
A6a) Value added tax – Excluded New excluded topic added:
topics • Making tax digital
A6b) The UK tax system and its New excluded topic added:
administration – Excluded • Extension of offshore
topics assessment time limits.

Table 2 – Amendments
Section and subject area Syllabus content
Guide to ACCA examination In order to provide certainty on

assessment examinable legislation to publishers,
learning providers and students, at
an earlier date, the cut-off date for
examinable legislation which is
passed outside of the Finance Act
has changed from 31 July to 31
May.
Excluded topics Those topics which are excluded

from the TX-UK syllabus and study
guide are also excluded from the
ATX-UK syllabus and study guide
unless expressly stated as an
additional topic.
All excluded topics in the ATX-UK
syllabus and study guide have been
reviewed and those which repeat
exclusions as stated in the TX-UK
syllabus and study guide have been
deleted. Unless these topics are
expressly stated as additional
topics, they remain excluded.
This review has been undertaken to
ensure consistency of treatment and
clarity for publishers, learning
providers and students.
A1c) Income from employment – Excluded topic removed as no
Excluded topics longer relevant:
• Employee shareholder
shares
A1d) Income from self-employment Part iv) removed as no longer
relevant:
• Identify the enhanced capital
allowances available in
respect of expenditure on
green technologies

A1g) The use of exemptions and Part (iii) added for clarification:
reliefs in deferring and • The threshold level of income
minimising income tax below which tapering of the
liabilities pensions annual allowance
does not apply.
A2b) The scope of the taxation of Part (vi) amended to reflect that
capital gains non-residents are now subject to
capital gains tax (CGT) on disposals
of all UK land and buildings and not
just residential property.
A3c) The basic principles of Part (i) amended to clarify that the
computing transfers of value related property rules are
examinable.
A3d) The liabilities arising on Part (viii) added for clarification:

chargeable lifetime transfers • Advise on the reduced rate of
and on the death of an inheritance tax payable when
individual a proportion of a person’s
estate is bequeathed to
charity
A4c) Taxable total profits – Excluded topic removed as no
Excluded topics longer relevant:
• The disposal of residential
property by a company
A4c) Taxable total profits - Part ii) removed as no longer

relevant:
• Identify the enhanced capital
allowances available in
respect of expenditure on
green technologies, including
the tax credit available in the
case of a loss making
company
A4f) The use of exemptions and Excluded topic removed as no
reliefs in deferring and longer relevant:
minimising corporation tax • Disincorporation relief
liabilities – Excluded topics
There have been no other amendments to the syllabus.

Advanced Taxation - United Kingdom (ATX-UK) : Syllabus and Study Guide

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Advanced Taxation - United Kingdom (ATX-UK) : Syllabus and Study Guide

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Advanced Taxation – United Kingdom (ATX-UK)

June 2020 to March 2021

© ACCA 2020-2021 All rights reserved.

© ACCA 2020-2021 All rights reserved.

1. Intellectual levels 2. Learning hours and

© ACCA 2020-2021 All rights reserved.

3. Guide to ACCA Strategic Professional

© ACCA 2020-2021 All rights reserved.

enabling students to demonstrate their

ACCA encourages students to take time

Time should be taken to ensure that all

The pass mark for all ACCA

© ACCA 2020-2021 All rights reserved.

4. Guide to ACCA For UK tax exams, examinations falling

Regulations issued or legislation passed

The term issued or passed relates to

The term effective relates to when

The study guide offers more detailed

© ACCA 2020-2021 All rights reserved.

5. Relational diagram linking Advanced Taxation –

This diagram indicates where students are expected to have underpinning

6. Overall aim of the syllabus

© ACCA 2020-2021 All rights reserved.

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

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

Relational diagram of the main capabilities

© ACCA 2020-2021 All rights reserved.

The syllabus builds on the basic

Computations will normally only be

Candidates are not expected to

© ACCA 2020-2021 All rights reserved.

Section A consists of two compulsory

Section B consists of two compulsory

Candidates will be expected to

The examination is a three hour 15

Tax rates, allowances and information

© ACCA 2020-2021 All rights reserved.

10. The syllabus

1. Income and income tax liabilities in 3. Taxation effects of the financial

B The impact of relevant taxes on 4. The mitigation of tax in the manner

© ACCA 2020-2021 All rights reserved.

5. Ethical and professional issues

6. Current issues in taxation.

D Communicating with clients, HM

2. Presentation of written information,

3. Conclusions reached with relevant

4. Assumptions made or limitations in

5. Other non-tax factors that should be

© ACCA 2020-2021 All rights reserved.

11. Detailed study guide ii) Advise on the availability of the

© ACCA 2020-2021 All rights reserved.

f) The comprehensive computation of Income from self employment:

© ACCA 2020-2021 All rights reserved.

2. Chargeable gains and capital v) Conclude on the capital gains tax

© ACCA 2020-2021 All rights reserved.

f) Gains and losses on the disposal of Excluded topics

© ACCA 2020-2021 All rights reserved.

• Sets of chattels in relation to these concepts to inheritance

© ACCA 2020-2021 All rights reserved.

ii) Distinguish between different The basic principles of computing

The scope of inheritance tax: The system by which inheritance tax

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a) The contents of the Taxation - provided via a personal service