Advanced Taxation – United Kingdom (ATX-UK)

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

June 2023 to March 2024

Designed to help with planning study and to provide

detailed information on what could be assessed in any
examination session

1 © ACCA 2023-2024 All rights reserved.

 Advanced Taxation – United Kingdom (ATX-UK)

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

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 Advanced Taxation – United Kingdom (ATX-UK)

1.Intellectual levels 2.Learning hours and

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

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 Advanced Taxation – United Kingdom (ATX-UK)

3.The structure of ACCA qualification

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 Advanced Taxation – United Kingdom (ATX-UK)

Strategic Professional
4. Guide to ACCA Essentials:
Strategic Business Leader is ACCA’s case
examination structure and study examination at Strategic Professional
delivery mode and from September 2023 is examined as a
closed book exam of 3 hours and 15
The pass mark for all ACCA Qualification minutes, including reading, planning and
examinations is 50%. reflection time which can be used flexibly
within the examination.
The structure and delivery mode of
examinations varies. Pre-seen information for the Strategic
Business Leader exam will be released two
Applied Knowledge weeks before the exam sitting. The pre-seen
The Applied Knowledge examinations information contains background and
contain 100% compulsory questions to contextual details in order for students to
encourage students to study across the familiarise themselves with the fictitious
breadth of each syllabus. These are organisation that they will be examined on
assessed by a two-hour computer based and the industry in which it operates.
examination.
The Strategic Business Leader exam will
Applied Skills contain new information in the form of
The Corporate and Business Law exam is a exhibits and students are required to
two-hour computer-based objective test complete several tasks. All questions are
examination for English and Global. compulsory and each examination will
contain a total of 80 technical marks and 20
For the format and structure of the professional skills marks.
Corporate and Business Law or Taxation
variant exams, refer to the ‘Approach to As this is a closed book exam, the pre-seen
examining the syllabus’ section of the information is also available within the
relevant syllabus and study guide. examination.

The other Applied Skills examinations Strategic Business Reporting is a three hour
(PM, TX-UK, FR, AA, and FM) contain a mix 15 minutes exam. It contains two sections
of objective and longer type questions with a and all questions are compulsory. This exam
duration of three hours for 100 marks. These contains four professional marks.
are assessed by a three-hour computer-
based exam. Prior to the start of each exam Options:
there will be time allocated for students to be The Strategic Professional Options are all
informed of the exam instructions. three hours 15 minutes computer-based
exams. All contain two sections and all
The longer (constructed response) question questions are compulsory.
types used in the Applied Skills exams
(excluding Corporate and Business Law) All option exams contain a total of 80
require students to effectively mimic what technical marks and 20 professional skills
they do in the workplace. Students will need marks.
to use a range of digital skills and
demonstrate their ability to use spread The question types used at Strategic
sheets and word processing tools in Professional require students to effectively
producing their answers, just as they would mimic what they would do in the workplace.
use these tools in the workplace. These
assessment methods allow ACCA to focus These exams offer ACCA the opportunity to
on testing students’ technical and application focus on the application of knowledge to
skills, rather than, for example, their ability to scenarios, using a range of tools including
perform simple calculations. word processor, spreadsheets and
presentation slides - not only enabling

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 Advanced Taxation – United Kingdom (ATX-UK)

students to demonstrate their technical and

professional skills but also their use of the
technology available to today’s accountants.

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

Students should ensure that all the

information and exam requirements are
properly read and understood.

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 Advanced Taxation – United Kingdom (ATX-UK)

5.Guide to ACCA
examination assessment
ACCA reserves the right to examine any For UK tax exams, examinations falling
learning outcome contained within the study within the period 1 June to 31 March will
guide. This includes knowledge, techniques, generally examine the Finance Act which
principles, theories, and concepts as was passed in the previous year. Therefore,
specified. For the financial accounting, audit exams falling in the period 1 June 2023 to
and assurance, law, and tax exams except 31 March 2024 will examine the Finance Act
where indicated otherwise, ACCA will 2022 and any examinable legislation which
publish examinable documents once a year is passed outside of the Finance Act before
to indicate exactly what regulations and 31 May 2022.
legislation could potentially be assessed
For additional guidance on the examinability
within identified examination sessions.
of specific tax rules and the depth in which
they are likely to be examined, reference
For most examinations (not tax), regulations
should be made to the relevant Finance Act
issued or legislation passed on or before 31
article written by the examining team and
August annually, will be examinable from 1 published on the ACCA website.
September of the following year to 31
August of the year after that. Please refer to None of the current or impending devolved
the examinable documents for the exam taxes for Scotland, Wales, and Northern
(where relevant) for further information. Ireland is, or will be, examinable.

Regulations issued or legislation passed in

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

The term issued or passed relates to when

regulation or legislation has been formally
approved.

The term effective relates to when regulation

or legislation must be applied to an entity’s
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.

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 Advanced Taxation – United Kingdom (ATX-UK)

6.Relational diagram linking Advanced Taxation – United

Kingdom (ATX-UK) with other exams

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

7. Approach to examining the syllabus

The Advanced Taxation (UK) exam builds upon the skills and knowledge examined in the
Taxation (UK) exam. At this stage students will be expected to demonstrate a
comprehensive knowledge of the taxes included in the syllabus and the ability to consider
the application of more than one tax in a given scenario. The study guide specifies the wide
range of technical understanding that is required to achieve a satisfactory standard at this
level.

The examination will also focus on the following professional skills and behaviours:

• Communication
• Analysis and evaluation
• Scepticism
• Commerical Acumen

Examination structure

The syllabus is assessed by a three hours 15 minutes examination, consisting of two

sections. In both sections students 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.

Section A

Section A will comprise a case-study worth 50 marks and testing multiple taxes. The 50
marks will comprise of 35 technical marks, 5 ethics marks and 10 professional skills marks.
All four professional skills will be examined in Section A.

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 Advanced Taxation – United Kingdom (ATX-UK)

Section B

Section B will contain two compulsory 25-mark questions, together covering both business
and personal tax issues. The 25 marks will comprise of 20 technical marks and five
professional skills marks. Section B questions will examine a combination of professional
skills appropriate to that question. Each question will examine a minimum of two professional
skills from analysis and evaluation, professional scepticism and commercial acumen.
Communication skills will not be examined in Section B.

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

8. Introduction to the syllabus

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

The Advanced Taxation - United Kingdom (ATX-UK) syllabus further develops the key
aspects of taxation introduced in the compulsory Taxation – United Kingdom (TX-UK)
syllabus within the Applied Skills module and extends the student’s 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 students 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 students 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.

Students at this level are expected to go beyond just the computational aspects of taxation.
Whilst it remains important that they are able to display a thorough understanding of the
calculative elements of the syllabus, this exam also seeks to develop their skills of analysis,
interpretation and communication. Students are expected to be able to use established tax
planning methods and consider current issues in taxation.

Computations will often only be required in support of explanations or advice and not in
isolation. However, purely calculative requirements may still feature as part of questions.

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

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

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 Advanced Taxation – United Kingdom (ATX-UK)

9. Main capabilities

On successful completion of this exam, students 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 Apply a range of professional skills in addressing requirements within the ATX-UK

examination in preparation for, or to support, current work experience

E Demonstrate employability and technology skills.

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

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 Advanced Taxation – United Kingdom (ATX-UK)

10. The syllabus

A Knowledge and understanding of the 3. Taxation effects of the financial

UK tax system through the study of decisions made by businesses
more advanced topics within the (corporate and unincorporated) and by
taxes studied previously and the individuals.
study of stamp taxes
4. Tax advantages and/or disadvantages of
1. Income and income tax liabilities in alternative courses of action.
situations involving further overseas
aspects and in relation to trusts, and the 5. Statutory obligations imposed in a given
application of additional exemptions and situation, including any time limits for
reliefs. action and the implications of non-
compliance.
2. Chargeable gains and capital gains tax
liabilities in situations involving further C Minimising and/or deferring tax
overseas aspects and in relation to liabilities by the use of standard tax
closely related persons and trusts, and planning measures
the application of additional exemptions
and reliefs. 1. Types of investment and other
expenditure that will result in a reduction
3. Inheritance tax in situations involving in tax liabilities for an individual and/or a
further aspects of the scope of the tax business.
and the calculation of the liabilities
arising, the principles of valuation and 2. Legitimate tax planning measures, by
the reliefs available, transfers of property which the tax liabilities arising from a
to and from trusts, overseas aspects and particular situation or course of action
further aspects of administration. can be mitigated.

4. Corporation tax liabilities in situations 3. The appropriateness of such investment,

involving overseas and further group expenditure or measures, given a
aspects and in relation to special types particular taxpayer’s circumstances or
of company, and the application of stated objectives.
additional exemptions and reliefs.
4. The mitigation of tax in the manner
5. Stamp taxes recommended, by reference to
numerical analysis and/or reasoned
6. Value added tax, tax administration and argument.
the UK tax system
5. Ethical and professional issues arising
B The impact of relevant taxes on from the giving of tax planning advice.
various situations and courses of
action, including the interaction of
D Professional skills
taxes
1. Communication
1. Taxes applicable to a given situation or
course of action and their impact. 2. Analysis and evaluation

2. Alternative ways of achieving personal or 3. Scepticism

business outcomes may lead to different
tax consequences. 4. Commercial acumen

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 Advanced Taxation – United Kingdom (ATX-UK)

E Employability and technology skills

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

2. Work on relevant response options,

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

3. Navigate windows and computer

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

4. Present data and information effectively,

using the appropriate tools.

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 Advanced Taxation – United Kingdom (ATX-UK)

11. Detailed study guide

A Apply further knowledge and v) Understand the relevance of the

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

b) The scope of income tax: [3] f) The comprehensive computation of

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

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 Advanced Taxation – United Kingdom (ATX-UK)

enterprise investment scheme and • The reduced anti-avoidance annual

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

The comprehensive computation of b) The scope of the taxation of capital

taxable income and the income tax gains: [3]
liability: i) Determine the tax implications of
• The child benefit tax charge. independent taxation and
• Charitable donations. transfers between spouses.
• Social security benefits apart from ii) Identify the concepts of
the State Retirement Pension. residence, domicile and deemed

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 Advanced Taxation – United Kingdom (ATX-UK)

domicile, and determine their f) Gains and losses on the disposal of

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

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 Advanced Taxation – United Kingdom (ATX-UK)

• Capital gains tax on disposals of • Computation of cost and indexed

indirect interests in UK land and cost within the s.104 TCGA 1992
buildings by non-residents. share pool.

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

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

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

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

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 Advanced Taxation – United Kingdom (ATX-UK)

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

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 Advanced Taxation – United Kingdom (ATX-UK)

• Knowledge that instalment payments c) Taxable total profits: [3]

may carry interest and the criteria to i) Identify qualifying research and
be met for instalment payments to be development expenditure, both
interest-bearing. capital and revenue, and
determine the relief available for
4. Corporation tax liabilities in situations small or medium sized enterprises
involving further overseas and group (SMEs).
aspects and in relation to special ii) Determine the tax treatment of
types of company, and the application non trading deficits on loan
of additional exemptions and reliefs. relationships.
iii) Recognise the alternative tax
a) The contents of the Taxation - United treatments of intangible assets
Kingdom (TX-UK) study guide, for and conclude on the best
corporation tax, under headings:[2] treatment for a given company.
• E1 The scope of corporation tax iv) Advise on the impact of the transfer
• E2 Taxable total profits pricing and thin capitalisation rules
• E3 Chargeable gains for companies on companies.
• E4 The comprehensive computation v) Advise on the restriction on the
of corporation tax liability use of losses on a change in
• E5 The effect of a group corporate ownership of a company.
structure for corporation tax vi) Identify the restriction on carried
purposes forward trading losses and capital
• E6 The use of exemptions and reliefs losses for companies with profits
in deferring and minimising over £5 million.
corporation tax liabilities
d) The comprehensive calculation of the
The following additional material is also corporation tax liability: [3]
examinable: i) Assess the impact of the OECD
model double tax treaty on
b) The scope of corporation tax: [3] corporation tax.
i) Identify and calculate corporation ii) Evaluate the meaning and
tax for companies with implications of a permanent
investment business. establishment.
ii) Close companies: iii) Identify and advise on the tax
implications of controlled foreign
• Apply the definition of a close
companies.
company to given situations
iv) Advise on the tax position of
• Conclude on the tax implications
overseas companies trading in
of a company being a close
the UK.
company or a close investment
v) Calculate double taxation relief.
holding company
iii) Identify and evaluate the
e) The effect of a group structure for
significance of accounting periods on
corporation tax purposes: [3]
administration or winding up.
i) Advise on the allocation of the
iv) Conclude on the tax treatment of
annual investment allowance
returns to shareholders after winding
between group or related
up has commenced.
companies.
v) Advise on the tax implications of
ii) Advise on the tax consequences
a purchase by a company of its
of a transfer of intangible assets.
own shares.
iii) Advise on the tax consequences
vi) Identify personal service
of a transfer of a trade and assets
companies and advise on the tax
where there is common control.
consequences of services being
iv) Understand the meaning of
provided via a personal service
consortium owned company and
company.
consortium member.

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 Advanced Taxation – United Kingdom (ATX-UK)

v) Advise on the operation of acquisition where qualifying

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

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 Advanced Taxation – United Kingdom (ATX-UK)

i) Advise on the stamp taxes payable • A2 Principal sources of revenue law

on transfers of shares and securities. and practice
ii) Advise on the stamp taxes payable • A3 The systems for self
on transfers of land. assessment and the making of
returns
c) The use of exemptions and reliefs in • A4 The time limits for the
deferring and minimising stamp taxes: [3] submission of information, claims
i) Identify transfers involving no and payment of tax, including
consideration. payments on account
ii) Advise on group transactions. • A5 The procedures relating to
compliance checks, appeals and
Excluded topics disputes
• A6 Penalties for non-compliance
The scope of stamp taxes:
• Leases. The following additional material is also
• Land and Buildings Transaction Tax examinable: [2]
(LBTT).
i) Advise on the increased
The liabilities arising on transfers: penalties which apply in relation
• The contingency principle. to offshore matters.
• Residential property.
• The systems by which stamp taxes Excluded topics
are administered.
Value added tax:
6. Value added tax, tax administration • The determination of the tax point.
and the UK tax system: • The contents of a valid VAT invoice.
• Special place of supply rules for
a) The contents of the Taxation - United business to consumer supplies of
Kingdom (TX-UK) study guide for value telecommunications, broadcasting
added tax (VAT) under headings: [2] and e-services.
• F1 The VAT registration • Disaggregation of business activities
requirements for VAT purposes.
• F2 The computation of VAT • Divisional registration.
liabilities • Making tax digital.
• F3 The effect of special schemes
The UK tax system and its
The following additional material is also Administration:
examinable:[3] • Extension of offshore assessment
time limits.
i) Advise on the VAT implications
of the supply of land and
buildings in the UK.
B The impact of relevant taxes
ii) Advise on the VAT implications on various situations and
of partial exemption. courses of action, including
iii) Advise on the application of the the interaction of taxes
capital goods scheme.
1. Identify and advise on the taxes
b) The contents of the Taxation - United applicable to a given course of action
Kingdom (TX-UK) study guide for the UK and their impact.[3]
tax system and its administration under
headings: [2] 2. Identify and understand that the
• A1 The overall function and alternative ways of achieving
purpose of taxation in a modern personal or business outcomes may
economy lead to different tax consequences.

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 Advanced Taxation – United Kingdom (ATX-UK)

a) Calculate the receipts from a transaction, 3. Advise on the appropriateness of

net of tax and compare the results of such investment, expenditure or
alternative scenarios and advise on the measures given a particular
most tax efficient course of action.[3] taxpayer’s circumstances or stated
objectives.[3]
3. Advise how taxation can affect the
financial decisions made by 4. Advise on the mitigation of tax in the
businesses (corporate and manner recommended by reference to
unincorporated) and by individuals. numerical analysis and/or reasoned
argument.[3]
a) Understand and compare and contrast
the tax treatment of the sources of 5. Be aware of the ethical and
finance and investment products professional issues arising from the
available to individuals.[3] giving of tax planning advice.[3]

b) Understand and explain the tax D Professional skills

implications of the raising of equity
and loan finance.[3] 1. Communication.
c) Explain the tax differences between a) Inform concisely, objectively and
decisions to lease, use hire unambiguously, adopting a suitable
purchase or purchase outright.[3] style and format, using appropriate
technology. [3]
d) Understand and explain the impact
of taxation on the cash flows of a b) Advise using compelling and logical
business.[3] arguments, demonstrating the ability to
counter argue where appropriate. [3]
4. Assess the tax advantages and
disadvantages of alternative c) Clarify and simplify complex issues to
courses of action.[3] convey relevant information in a way
that adopts an appropriate tone and is
5. Understand the statutory easily understood by and reflects the
obligations imposed in a given requirements of the intended
situation, including any time audience.[3]
limits for action and advise on the
implications of non-compliance.[3] 2. Analysis and evaluation.

C Minimise and/or defer tax a) Investigate relevant information from a

liabilities by the use of range of sources, using appropriate
analytical techniques to establish
standard tax planning reasons and causes of issues, assist in
measures decision-making and to identify
opportunities or solutions. [3]
1. Identify and advise on the types of
investment and other expenditure that b) Consider information, evidence and
will result in a reduction in tax findings carefully, reflecting on their
liabilities for an individual and/or a implications and how they can be used
business.[3] to best support the interests of the
individual, entity or wider business
2. Advise on legitimate tax planning organisation. [3]
measures, by which the tax liabilities
arising from a particular situation or c) Assess and apply appropriate
course of action can be mitigated.[3] judgement when considering ethical,
professional or other technical issues;

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 Advanced Taxation – United Kingdom (ATX-UK)

when making conclusions or b) Recognise key issues in a given

recommendations, taking into account scenario and use judgement in
the implications of such decisions on the proposing and recommending
entity or individual affected.[3] commercially viable solutions. [3]

d) Appraise information objectively in order c) Offer solutions which are practical and
to effectively prioritise issues; identifying commercial in the context of the
missing information and exploring scenario being considered
suitable alternatives when making
decisions, devising courses of action or d) Show insight and perception in
providing conclusions or understanding key tax drivers of an
recommendations. individual or entity, demonstrating
acumen in arriving at appropriate
e) Communicate conclusions reached, recommendations. [3]
together, where necessary with relevant
supporting computations.[3] E Employability and technology
skills
3. Scepticism.
1. Use computer technology to
a) Explore the underlying reasons for efficiently access and manipulate
issues, applying an attitude of a relevant information.
questioning mind where appropriate,
beyond what is immediately apparent. [3] 2. Work on relevant response options,
using available functions and
b) Question opinions, assertions and technology, as would be required in
assumptions by seeking justifications the workplace.
and obtaining sufficient evidence for
either their support and acceptance, or 3. Navigate windows and computer
rejection. [3] screens to create and amend
responses to exam requirements,
c) Challenge and critically assess the using the appropriate tools.
information presented or decisions or
recommendations made, where this is 4. Present data and information
clearly justified, in the wider effectively, using the appropriate
professional, ethical, organisational or tools.
public interest. [3]

d) State and explain 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.[3]

4. Commercial acumen.

a) Demonstrate awareness of
organisational and external and other
non-tax factors which will affect
decisions with regard to tax taken by an
individual or entity. [3]

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 Advanced Taxation – United Kingdom (ATX-UK)

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

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

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

Table 1 – Additions

Section and subject area Syllabus content and rationale

D Professional skills This section reflects the additional

professional skills required for the
ATX- UK examination. It replaces
the previous Section D
(Communicate with clients, HM
Revenue and Customs and other
professionals in an appropriate
manner) which focussed solely on
the skill of communication.

Table 2 – Deletions

Section and subject area Syllabus content and rationale

A4c(i) Taxable total profits – Research and development relief for

Excluded topics large companies has been removed
from the syllabus and now appears
within the list of specific exclusions
under A(4).

C Minimise and/or defer tax The following item has now been
liabilities by the use of removed from the syllabus;
standard tax planning Item C(6) - Current issues in
measures taxation

There have been no other amendents to the syllabus

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