Advanced Taxation - United Kingdom (ATX-UK) (P6) : Syllabus and Study Guide

June 2018 to
March 2019
Advanced
Taxation –
United Kingdom
(ATX-UK) (P6)
Syllabus and study guide

Advanced Taxation – United Kingdom (ATX-UK) (P6)
Detailed syllabus
Guide to structure of the
syllabus and study guide This shows the breakdown of the main
capabilities (sections) of the syllabus
Overall aim of the syllabus into subject areas. This is the blueprint
for the detailed study guide.
This explains briefly the overall objective
of the syllabus and indicates in the
broadest sense the capabilities to be Approach to examining the syllabus
developed within the exam.
This section briefly explains the
Relational diagram linking Advanced structure of the examination and how it
Taxation – United Kingdom (ATX-UK) is assessed.
(P6) with other ACCA exams
This diagram shows direct and indirect Study Guide

links between this exam and other
exams preceding or following it. It This is the main document that students,
indicates where you are expected to education and content providers should
have underpinning knowledge and use as the basis of their studies,
where it would be useful to review instruction and materials. Examinations
previous learning before undertaking will be based on the detail of the study
study. guide which comprehensively identifies
what could be assessed in any
Main capabilities examination session. The study guide is
a precise reflection and breakdown of
The aim of the syllabus is broken down the syllabus. It is divided into sections
into several main capabilities which based on the main capabilities identified
divide the syllabus and study guide into in the syllabus. These sections are
discrete sections. divided into subject areas which relate to
the sub-capabilities included in the
Relational diagram of the main detailed syllabus. Subject areas are
capabilities broken down into sub-headings which
describe the detailed outcomes that
This diagram illustrates the flows and could be assessed in examinations.
links between the main capabilities These outcomes are described using
(sections) of the syllabus and should be verbs indicating what exams may
used as an aid to planning teaching and require students to demonstrate, and the
learning in a structured way. broad intellectual level at which these
may need to be demonstrated
Syllabus rationale (*see intellectual levels below).
This is a narrative explaining how the

syllabus is structured and how the main
capabilities are linked. The rationale
also explains in further detail what the
examination intends to assess and why.
© ACCA 2018-2019 All rights reserved.

Intellectual Levels Learning Hours and

Education 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 qualifications are
Professional exams
recognised and valued by governments,
are assessed.
regulatory authorities and employers
Each subject area in the detailed study across all sectors. To this end, ACCA
guide included in this document is given qualifications are currently recognised
a 1, 2, or 3 superscript, denoting on the education frameworks in several
intellectual level, marked at the end of countries. Please refer to your national
each relevant line. This gives an education framework regulator for
indication of the intellectual depth at further information.
which an area could be assessed within
the examination. However, while level 1 Each syllabus contains between 23 and
broadly equates with Applied 35 main subject area headings
Knowledge, level 2 equates to Applied depending on the nature of the subject
Skills and level 3 to Strategic and how these areas have been broken
Professional, some lower level skills can down.
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.

Guide to ACCA ACCA’s regulatory approved quality

assurance process.
Examination Structure
The structure of examinations varies The total exam time is therefore 3 hours
and 20 minutes. Prior to the start of the
within and between levels.
exam candidates are given an extra 10
The Applied Knowledge examinations minutes to read the exam instructions.
contain 100% compulsory questions to
Paper-based exams
encourage candidates to study across
the breadth of each syllabus.
For paper-based exams 15 minutes are
added to the three hours to reflect the
The Applied Knowledge exams are
manual effort required as compared to
assessed by equivalent two-hour
computer based and paper based computer-based exams. All paper-
based and computer-based questions
examinations.
have been subject to the same quality
The Corporate and Business Law exam assurance process. There will be time
is a two- hour computer based objective awarded by the invigilator to read the
exam instructions.
test examination also available as a
paper based version.
Strategic Business Leader is ACCA’s
case study examination at the Strategic
The other Applied Skills examinations
Professional level and is examined as a
contain a mix of objective and longer
type questions with a duration of three closed book exam of four hours,
hours for 100 marks, these questions including reading, planning and
reflection time which can be used
directly contribute towards the candidate
result. These exams are available in flexibly within the examination. There is
computer-based and paper-based no pre-seen information and all exam
related material, including case
formats. Prior to the start of each exam
information and exhibits are available
there will be time allocated for students
to be informed of the exam instructions. within the examination. Strategic
Business leader is an exam based on
Computer-based exams one main business scenario which
involves candidates completing several
For the Applied Skills computer-based tasks within which additional material
may be introduced. All questions are
exams candidates will be delivered an
extra 10 marks of objective test content compulsory and each examination will
(either five single OT questions or five contain a total of 80 technical marks and
20 Professional Skills marks. The detail
OT questions based around a single
of the structure of this exam is described
scenario), for which candidates are
given an extra 20 minutes. These in the Strategic Business Leader
syllabus and study guide document.
questions are included to ensure
fairness, reliability and security of
exams. These questions do not directly The other Strategic Professional exams
contribute towards the candidate’s are all of three hours and 15 minutes
duration. All contain two
score. Candidates will not be able to
Sections and all questions are
differentiate between the questions that
contribute to the result and those that do compulsory. These exams all contain
four professional marks. The detail of
not. All questions have been subject to

the structure of each of these exams is

described in the individual syllabus and
study guide documents.
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 writing in their answer books.
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%.

Guide to ACCA be examinable even if the effective date

Examination Assessment is in the future.
This syllabus and study guide is valid for The term issued or passed relates to
exams from June 2018 to March 2019. when regulation or legislation has been
In June 2018, the first session of a new formally approved.
exam year for tax, a new format will be
The term effective relates to when
introduced for the P6 Advanced
regulation or legislation must be applied
Taxation (UK) exam, to align with the
to an entity transactions and business
formats that will be introduced in all of
practices.
the Options exams from September
2018. From the September session, a The study guide offers more detailed
new naming convention is being guidance on the depth and level at
introduced for all of the exams in the which the examinable documents will be
ACCA Qualification, so from that examined. The study guide should
session, the name of the exam will be therefore be read in conjunction with the
Advanced Taxation – United Kingdom examinable documents list.
(ATX-UK). Since this name change
takes place during the validity of this For UK tax exams, examinations falling
syllabus, both the old and new names within the year 1 June to 31 March will
have been used. For clarity, both generally examine the Finance Act
names have been used for any exams which was passed in the previous year.
referred to in this syllabus. Therefore, exams falling in the year 1
June 2018 to 31 March 2019 will
ACCA reserves the right to examine examine the Finance Act 2017 (which
anything contained within the study received Royal Assent on 27 April 2017)
guide at any examination session. This and any examinable legislation which is
includes knowledge, techniques, passed outside of the Finance Act
principles, theories, and concepts as before 31 July 2017.
specified. For the financial accounting,
Given the unexpected General Election
audit and assurance, law and tax exams
in June 2017, in order to provide
except where indicated otherwise, certainty, this is the latest Finance Act
ACCA will publish examinable which will be examined in exams falling
documents once a year to indicate within this exam year. If there are any
exactly what regulations and legislation further Finance Acts 2017 they will not
could potentially be assessed within be examinable in exams falling in the
identified examination sessions. year 1 June 2018 to 31 March 2019,
regardless of when they receive Royal
For most examinations (not tax), Assent.
regulations issued or legislation passed
on or before 31 August annually, will be For additional guidance on the
examinable from 1 September of the examinability of specific tax rules and
following year to 31 August of the year the depth in which they are likely to be
after that. Please refer to the examined, reference should be made to
examinable documents for the the relevant Finance Act article written
examination (where relevant) for further by the examining team and published on
the ACCA website.
information.
Regulations issued or legislation passed None of the current or impending

devolved taxes for Scotland, Wales, and
in accordance with the above dates may
Northern Ireland is, or will be,
examinable.


syllabus and study guide
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.
Aim
To apply relevant knowledge and skills
and exercise professional judgement in
providing relevant information and
advice to individuals and businesses on Advanced Taxation –
the impact of the major taxes on United Kingdom
financial decisions and situations. (ATX-UK) (P6)
Relational diagram linking
Advanced Taxation – United
Kingdom (ATX-UK) (P6) with other Taxation –
ACCA exams United Kingdom
(TX-UK) (F6)
This diagram shows direct and indirect
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) (P6) by Taxation – United Kingdom (TX-UK) (F6). These
links are shown as solid line arrows. Other exams only have indirect relationships
with each other such as links existing between the accounting and auditing exams.
The links between these are shown as dotted line arrows. This diagram indicates
where you are expected to have underpinning knowledge and where it would be
useful to review previous learning before undertaking study.

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.

Rationale aspects of taxation. Instead this exam

seeks to develop candidates’ skills of
analysis, interpretation and
The Advanced Taxation - United communication. Candidates are
Kingdom (ATX-UK) (P6) syllabus further expected to be able to use established
develops the key aspects of taxation tax planning methods and consider
introduced in the compulsory Taxation – current issues in taxation.
United Kingdom (TX-UK) (F6) 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

Detailed syllabus B The impact of relevant taxes on

various situations and courses of
action, including the interaction of
A Knowledge and understanding of taxes
the UK tax system through the
study of more advanced topics 1. Taxes applicable to a given situation
within the taxes studied or course of action and their impact.
previously and the study of stamp
taxes. 2. Alternative ways of achieving
personal or business outcomes may
1. Income and income tax liabilities in lead to different tax consequences.
situations involving further overseas
aspects and in relation to trusts, and 3. Taxation effects of the financial
the application of additional decisions made by businesses
exemptions and reliefs. (corporate and unincorporated) and
by individuals.
2. Chargeable gains and capital gains
tax liabilities in situations involving 4. Tax advantages and/or
further overseas aspects and in disadvantages of alternative
relation to closely related persons courses of action.
and trusts, and the application of
additional exemptions and reliefs. 5. Statutory obligations imposed in a
given situation, including any time
3. Inheritance tax in situations involving limits for action and the implications
further aspects of the scope of the of non-compliance.
tax and the calculation of the
liabilities arising, the principles of C Minimising and/or deferring tax
valuation and the reliefs available, liabilities by the use of standard
transfers of property to and from tax planning measures
trusts, overseas aspects and further
aspects of administration. 1. Types of investment and other
expenditure that will result in a
4. Corporation tax liabilities in reduction in tax liabilities for an
situations involving overseas and individual and/or a business.
further group aspects and in relation
to special types of company, and the 2. Legitimate tax planning measures,
application of additional exemptions by which the tax liabilities arising
and reliefs. from a particular situation or course
of action can be mitigated.
5. Stamp taxes
3. The appropriateness of such
6. Value added tax, tax administration investment, expenditure or
and the UK tax system measures, given a particular
taxpayer’s circumstances or stated
objectives.
4. The mitigation of tax in the manner

recommended, by reference to

numerical analysis and/or reasoned

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.

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 and question 2 has 25 marks. There will also be five ethics marks and four
professional skills marks available in 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.

Study Guide ii) Advise on the availability of the

remittance basis to UK resident
individuals [2]
A Apply further knowledge iii) Advise on the tax position of
individuals coming to and leaving
and understanding of the the UK
UK tax system through the iv) Determine the income tax
study of more advanced treatment of overseas income
topics within the taxes v) Understand the relevance of the
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) (F6) study lump sum receipts
guide for income tax and national iii) Advise on the overseas aspects
insurance, under headings:[2] of income from employment,
including travelling and
• B1 The scope of income tax subsistence expenses
• B2 Income from employment iv) Identify personal service
• B3 Income from self-employment companies and advise on the tax
• B4 Property and investment consequences of providing
income services via a personal service
• B5 The comprehensive company
computation of taxable income
and the income tax liability d) Income from self employment: [3]
• B6 National insurance i) Advise on a change of
contributions for employed and accounting date
self-employed persons ii) Advise on the relief available for
• B7 The use of exemptions and trading losses following the
reliefs in deferring and transfer of a business to a
minimising income tax liabilities company
iii) Recognise the tax treatment of
The following additional material is overseas travelling expenses
also examinable: iv) Advise on the allocation of the
annual investment allowance
b) The scope of income tax: [3] between related businesses
i) Explain and apply the concepts v) Identify the enhanced capital
of residence and domicile and allowances available in respect
advise on the relevance to of expenditure on green
income tax technologies.[2]

e) Property and investment income: [3] • Employee shareholder

i) Advise on the tax implications of shares
jointly held assets
ii) Recognise the tax treatment of Income from self employment:
savings income paid net of tax • The 100% first year
iii) Income from trusts and allowance for renovating
settlements: Understand the business premises in
income tax position of trust disadvantaged areas and
beneficiaries flats above shops.
• Capital allowances for
f) The comprehensive computation of agricultural buildings,
taxable income and the income tax patents, scientific research
liability:[3] and know how.
i) Understand the allocation of the • Enterprise zones.
personal allowance to different • The allocation of notional
categories of income. profits and losses for a
ii) Advise on the income tax partnership.
position of the income of minor • Farmers averaging of profits.
children • The averaging of profits for
authors and creative artists.
g) 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.
i) Understand and apply the rules
• Investment income of a
relating to investments in the
partnership
seed enterprise investment
scheme and the enterprise
Property and investment income:
investment scheme [3]
• The deduction for
ii) Understand and apply the rules
expenditure by landlords on
relating to investments in
venture capital trusts [3] energy-saving items
• Pre-owned assets
Excluded topics
National insurance:
The scope of income tax: • The calculation of directors’
• Details of specific anti- national insurance on a
avoidance provisions, except month by month basis.
as stated in the study guide. • The offset of trading losses
• Profits of non-residents from against non-trading income
a trade of dealing in or and capital gains.
developing land in the UK.
Income from trusts and settlements:
Income from employment: • The computation of income
• Explanation of the PAYE tax payable by trustees.
system. • Overseas aspects.
• The calculation of a car
benefit where emission The comprehensive computation of
figures are not available. taxable income and the income tax
liability:

• The blind person’s allowance • C6 The use of exemptions

and the married couple’s age and reliefs in deferring and
allowance. minimising tax liabilities
• Tax credits. arising on the disposal of
• Maintenance payments. capital assets
• Charitable donations.
• Social security benefits apart The following additional material is
from the State Retirement also examinable:
Pension.
• The £10,000 anti-avoidance b) The scope of the taxation of capital
annual allowance applicable gains: [3]
to taxpayers accessing their i) Determine the tax implications of
pension flexibly independent taxation and
transfers between spouses
The use of exemptions and reliefs in ii) Identify the concepts of
deferring and minimising income tax residence and domicile and
liabilities: determine their relevance to
• The conditions that need to be capital gains tax
satisfied for pension schemes to iii) Advise on the availability of the
be registered by HM Revenue remittance basis to non-UK
and Customs. domiciled individuals.[2]
• The transfer of pension benefits iv) Determine the UK taxation of
on death foreign gains, including
double taxation relief
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 residential property 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) (F6) study partner in a partnership on the
guide for chargeable gains for disposal of a partnership asset
individuals under headings:[2]
c) Capital gains tax and trusts:
• C1 The scope of the taxation
i) Advise on the capital gains tax
of capital gains
implications of transfers of
• C2 The basic principles of
property into trust. [3]
computing gains and losses
ii) Advise on the capital gains tax
• C3 Gains and losses on the implications of property passing
disposal of movable and absolutely from a trust to a
immovable property beneficiary.[2]
• C4 Gains and losses on the
disposal of shares and d) The basic principles of computing
securities gains and losses: [3]
• C5 The computation of i) Identify connected persons for
capital gains tax capital gains tax purposes and

advise on the tax implications of iv) Establish the relief for capital
transfers between connected losses on shares in unquoted
persons trading companies [3]
ii) Advise on the impact of dates of
disposal and conditional g) The use of exemptions and reliefs in
contracts deferring and minimising tax
iii) Evaluate the use of capital losses liabilities arising on the disposal of
in the year of death capital assets: [3]
i) Understand and apply enterprise
e) Gains and losses on the disposal of investment scheme reinvestment
movable and immovable property: [3] relief
i) Advise on the tax implications of ii) Understand and apply seed
a part disposal, including small enterprise investment scheme
part disposals of land reinvestment relief
ii) Determine the gain on the iii) Advise on the availability of
disposal of leases and entrepreneurs’ relief in relation to
wasting assets associated disposals
iii) Establish the tax effect of capital iv) Understand and apply the relief
sums received in respect of the that is available on the transfer of
loss, damage or destruction of an unincorporated business to a
an asset limited company
iv) Advise on the tax effect of v) Understand the capital gains tax
making negligible value implications of the variation of
claims wills
v) Determine when capital gains tax
can be paid by instalments and Excluded topics
evaluate when this would be
advantageous to taxpayers The scope of the taxation of capital
gains:
f) Gains and losses on the disposal of • Detailed knowledge of the
shares and securities: [3] statements of practice on
i) Extend the explanation of the partnership capital gains.
treatment of rights issues to • Deemed disposals on a
include the small part disposal change in the profit sharing
rules applicable to rights issues ratio (PSR) of a partnership
ii) Define a qualifying corporate
bond (QCB), and understand Capital gains tax and trusts:
what makes a corporate bond • Overseas aspects of capital
non-qualifying. Understand the gains tax and trusts.
capital gains tax implications of • The computation of capital
the disposal of QCBs in gains tax payable by
exchange for cash or shares trustees.
iii) Apply the rules relating to • Transfers of property to or
reorganisations, reconstructions from trustees prior to 22
and amalgamations and March 2006.
advise on the most tax efficient • Knowledge of situations
options available in given where property is transferred
circumstances between trusts or where the

terms or nature of the trust is 3. Inheritance tax in situations

altered. involving further aspects of the
• Knowledge of situations scope of the tax and the
where property within a trust calculation of the liabilities
with an immediate post-death arising, the principles of valuation
interest passes to the spouse and the reliefs available, transfers
or civil partner of the settlor of property to and from trusts,
on the death of the life overseas aspects and further
tenant. aspects of administration
• Knowledge of the special
rules concerning trusts for a) The contents of the Taxation -
the disabled, trusts for United Kingdom (TX-UK) (F6) study
bereaved minors, transitional guide for inheritance tax under
serial interest trusts and age headings:[2]
18 to 25 trusts. • D1 The basic principles of
computing transfers of value
The basic principles of computing • D2 The liabilities arising on
gains and losses: the chargeable lifetime
• Assets held at 31 March transfers and on the death of
1982. an individual
• Relief for losses on loans • D3 The use of exemptions in
made to traders. deferring and minimising
inheritance tax liabilities
Gains and losses on the disposal of • D4 Payment of inheritance
movable and immovable property: tax
• The detailed calculations for
chattels where the cost or The following additional material is
proceeds are less than also examinable:
£6,000, other than
knowledge of the exemption b) The scope of inheritance tax:
where both cost and i) Explain the concepts of domicile
proceeds are less than and deemed domicile and
£6,000. understand the application of
• 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]
v) Identify and advise on the tax
Gains and losses on the disposal of implications of associated
shares and securities: operations [2]
• Computation of cost and
indexed cost within the s.104 c) The basic principles of computing
TCGA 1992 share pool. transfers of value:
i) Advise on the principles of
valuation[3]

ii) Advise on the availability of inheritance tax liabilities, as

business property relief and mentioned in the sections above
agricultural property relief.[3]
iii) Identify exempt transfers.[2] g) The system by which inheritance tax
is administered, including the
d) The liabilities arising on chargeable instalment option for the payment of
lifetime transfers and on the death of tax:
an individual: [3] i) Identify the occasions on which
i) Advise on the tax implications of inheritance tax may be paid by
chargeable lifetime transfers instalments.[2]
ii) Advise on the tax implications of ii) Advise on the due dates, interest
transfers within seven and penalties for inheritance tax
years of death purposes.[3]
iii) Advise on the tax liability arising
on a death estate Excluded topics
iv) Advise on the relief for the fall in
value of lifetime gifts The scope of inheritance tax:
v) Advise on the operation of quick • Pre 18 March 1986 lifetime
succession relief transfers.
vi) Advise on the operation of • Transfers of value by close
double tax relief for inheritance companies.
tax
vii) Advise on the inheritance tax The liabilities arising on chargeable
effects and advantages of the lifetime transfers and on the death of
variation of wills an individual:
• Double grossing up on death.
e) The liabilities arising in respect of • Post mortem reliefs.
transfers to and from trusts and on • Relief on relevant business
property within property and agricultural property
trusts: given as exempt legacies.
i) Define a trust [2] • Detailed knowledge of the
ii) Distinguish between different double charges legislation.
types of trust [3] • The protection of the residence
iii) Advise on the inheritance tax nil rate band where an individual
implications of transfers of downsizes to a less valuable
property into trust [3] property or where a property is
iv) Advise on the inheritance tax disposed of.
implications of property passing • Nominating which property
absolutely from a trust to a
should qualify for the residence
beneficiary [2]
nil rate band where there is more
v) Identify the occasions on which than one residence.
inheritance tax is payable by
trustees [3]
Computing transfers of value:
• Valuation of an annuity or an
f) The use of exemptions and reliefs in
interest in possession where the
deferring and minimising inheritance
trust interest is subject to an
tax liabilities: [3]
annuity.
i) Advise on the use of reliefs and
exemptions to minimise • Woodlands relief.

• Conditional exemption for • E3 Chargeable gains for

heritage property. companies
• E4 The comprehensive
Inheritance tax and trusts: computation of the corporation
• IHT aspects of discretionary tax liability
trusts prior to 27 March 1974. • E5 The effect of a group
• Trusts created prior to 22 March corporate structure for
2006. corporation tax purposes
• Computation of ten year charges • E6 The use of exemptions and
and exit charges. reliefs in deferring and
• The computation of inheritance minimising corporation tax
tax payable by trustees of an liabilities
immediate post-death interest
trust. The following additional material is
• Overseas aspects of inheritance also examinable:
tax and trusts.
• The conditions that had to be b) The scope of corporation tax: [3]
satisfied for a trust to be an i) Identify and calculate corporation
accumulation and maintenance tax for companies with
trust. investment business.
• Knowledge of situations where ii) Close companies:
property is transferred between • Apply the definition of a
trusts or where the terms or close company to given
nature of the trust is altered. situations
• Knowledge of situations where • Conclude on the tax
property within a trust with an implications of a
immediate post-death interest company being a close
passes to the spouse or civil company or a close
partner of the settlor on the investment holding
death of the life tenant. company
• Knowledge of the special rules iii) Identify and evaluate the
concerning trusts for the significance of accounting
disabled, trusts for bereaved periods on administration or
minors, transitional serial interest winding up
trusts and age 18 to 25 trusts. iv) Conclude on the tax treatment of
returns to shareholders after
4. Corporation tax liabilities in winding up has commenced
situations involving further v) Advise on the tax implications of
overseas and group aspects and a purchase by a company of its
in relation to special types of own shares
company, and the application of vi) Identify personal service
additional exemptions and reliefs companies and
advise on the tax consequences
a) The contents of the Taxation - of services being provided via a
United Kingdom (TX-UK) (F6) study personal service 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

capital and revenue, and between group or related

determine the reliefs available by companies
reference to the size of the ii) Advise on the tax consequences
individual company/group of a transfer of intangible
ii) Recognise the relevance of a assets
company generating profits iii) Advise on the tax consequences
attributable to patents of a transfer of a trade and
iii) Identify the enhanced capital assets where there is common
allowances available in respect control
of expenditure on green iv) Understand the meaning of
technologies, including the tax consortium owned company and
credit available in the case of a consortium member [2]
loss making company v) Advise on the operation of
iv) Determine the tax treatment of consortium relief
non trading deficits on loan vi) Determine pre-entry losses and
relationships understand their tax treatment
v) Recognise the alternative tax vii) Determine the degrouping
treatments of intangible assets charge where a company leaves
and conclude on the best a group within six years of
treatment for a given company receiving an asset by way of a
vi) Advise on the impact of the no gain/no loss transfer
transfer pricing and thin viii) Determine the effects of the anti-
capitalisation rules on avoidance provisions, where
companies arrangements exist for a
vii) Advise on the restriction on the company to leave a group
use of losses on a change in ix) Advise on the tax treatment of an
ownership of a company overseas branch
x) Advise on the relief for trading
d) The comprehensive calculation of losses incurred by an overseas
the corporation tax liability: [3] subsidiary
i) Assess the impact of the OECD
model double tax treaty on f) The use of exemptions and reliefs in
corporation tax deferring and minimising corporation
ii) Evaluate the meaning and tax liabilities: [3]
implications of a permanent i) Advise on the availability, and
establishment the application of
iii) Identify and advise on the tax disincorporation relief
implications of controlled ii) Determine the application of the
foreign companies substantial shareholdings
iv) Advise on the tax position of exemption
overseas companies trading in
the UK Excluded topics
v) Calculate double taxation relief
The scope of corporation tax:
e) The effect of a group structure for • Details of specific anti-
corporation tax purposes: [3] avoidance provisions, except
i) Advise on the allocation of the as stated in the Study Guide.
annual investment allowance

• Profits of non-residents from c) The use of exemptions and reliefs in

a trade of dealing in or deferring and minimising stamp
developing land in the UK. taxes: [3]
i) Identify transfers involving no
Taxable total profits: consideration
• The disposal of residential ii) Advise on group transactions
property by a company
• Tax avoidance involving d) Understand and explain the systems
carry forward losses by which stamp taxes are
• Diverted profits tax administered.[2]
The comprehensive calculation of Excluded topics

the corporation tax liability:
• Corporation tax rates for The scope of stamp taxes:
companies in the process of • Leases
winding up. • Land and Buildings
• Relief for overseas tax as an Transaction Tax (LBTT)
expense.
• Detailed knowledge of The liabilities arising on transfers:
specific double taxation • The contingency principle.
agreements. • Residential property held by
• Migration of a UK resident non-natural persons.
company.
• Mixer companies. The systems by which stamp taxes
• Detailed computational are administered:
questions on the carry back • Detailed rules on interest and
and carry forward of penalties.
unrelieved foreign tax.
• Quarterly accounting for 6. Value added tax, tax
income tax. administration and the UK tax
system:
5. Stamp taxes (stamp duty, stamp a) The contents of the Taxation -
duty reserve tax, and stamp duty United Kingdom (TX-UK) (F6) study
land tax) guide for value added tax (VAT)
under headings:
a) The scope of stamp taxes: [3] • F1 The VAT registration
i) Identify the property in respect of requirements
which stamp taxes are • F2 The computation of VAT
payable. liabilities
• F3 The effect of special
b) Identify and advise on the liabilities schemes
arising on transfers. [3]
i) Advise on the stamp taxes The following additional material is
payable on transfers of shares also examinable:
and securities
ii) Advise on the stamp taxes i) Advise on the VAT implications
payable on transfers of land of the supply of land and
buildings in the UK

ii) Advise on the VAT implications • Divisional registration.

of partial exemption
iii) Advise on the application of the B The impact of relevant
capital goods scheme
taxes on various
b) The contents of the Taxation - situations and courses of
United Kingdom (TX-UK) (F6) study action, including the
guide for the UK tax system and its interaction of taxes
administration under headings:
• A1 The overall function and 1. Identify and advise on the taxes
purpose of taxation in a applicable to a given course of
modern economy action and their impact.[3]
• A2 Principal sources of
revenue law and practice 2. Identify and understand that the
• A3 The systems for self alternative ways of achieving
assessment and the making personal or business outcomes
of returns may lead to different tax
• A4 The time limits for the consequences
submission of information,
claims and payment of tax, a) Calculate the receipts from a
including payments on transaction, net of tax and compare
account the results of alternative scenarios
• A5 The procedures relating and advise on the most tax efficient
to compliance checks, course of action.[3]
appeals and disputes
• A6 Penalties for non- 3. Advise how taxation can affect
compliance the financial decisions made by
businesses (corporate and
i) Advise on the increased unincorporated) and by
penalties which apply in relation individuals
to offshore matters. [2]
a) Understand and compare and
Excluded topics contrast the tax treatment of the
sources of finance and investment
Value added tax: products available to individuals.[3]
• The determination of the tax
point. b) Understand and explain the tax
• The contents of a valid VAT implications of the raising of equity
invoice. and loan finance.[3]
• Do it yourself builders.
• Second hand goods scheme. c) Explain the tax differences between
• Retailers’ schemes. decisions to lease, use hire
• Schemes for farmers. purchase or purchase outright.[3]
• Special place of supply rules for
business to consumer supplies d) Understand and explain the impact
of telecommunications, of taxation on the cash flows of a
broadcasting and e-services. business.[3]
• Disaggregation of business
activities for VAT purposes.

4. Assess the tax advantages and D Communicate with clients,

disadvantages of alternative
courses of action.[3]
HM Revenue and Customs
and other professionals in
5. Understand the statutory an appropriate manner
obligations imposed in a given
situation, including any time 1. Communicate advice,
limits for action and advise on the recommendations and
implications of non-compliance.[3] information in the required
format:[3]
C Minimise and/or defer tax
liabilities by the use of For example the use of:
• Reports
standard tax planning • Letters
measures • Memoranda
• Meeting notes
1. Identify and advise on the types
of investment and other 2. Present written information, in
expenditure that will result in a language appropriate to the
reduction in tax liabilities for an purpose of the communication
individual and/or a business.[3] and the intended recipient.[3]
2. Advise on legitimate tax planning 3. Communicate conclusions

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

Summary of changes to Advanced Taxation - United

Kingdom (ATX-UK) (P6)
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
A3 A3d) The liabilities arising on Excluded topics added for residence

chargeable lifetime transfers nil rate band:
and on the death of an • The protection of the
individual residence nil rate band
where an individual
downsizes to a less valuable
property or where a property
is disposed of.
• Nominating which property
should qualify for the
residence nil rate band
where there is more than one
residence.
Table 2 – Deletions
A1 A1c) Income from Employee shareholder shares now

employment removed and included in Excluded
topics
A6 A6a) Value added tax, tax Disaggregation of business activities

administration and the UK tax for VAT purposes now removed and
system included in Excluded topics
A6 A6a) Value added tax, tax Divisional registration now removed

administration and the UK tax and included in Excluded topics
system
There have been no other amendments to the syllabus.

Advanced Taxation - United Kingdom (ATX-UK) (P6) : Syllabus and Study Guide

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