year end. Damian personally owns 10% of the ordinary issued share capital of Linden Limited, for which he paid
￡10,000 in June 1998. He estimates that the current market value of Linden Limited is ￡9 million and that the
company will make taxable profits of ￡1·4 million in the forthcoming year to 31 July 2007.
(a) Damian believes that Linden Limited should conduct its activities in a socially responsible manner and to this
end has proposed that in future all cars purchased by the company should be low emission vehicles. The sales
director has stated that several of his staff, who are the main recipients of company cars, other than the directors,
are extremely unhappy with this proposal, perceiving it as downgrading their value and status.
The cars currently provided to the sales staff have a list price of ￡19,600, on which Linden Limited receives a
bulk purchase discount of 6% from the dealer, and a CO2 emission rate of 168 grams/kilometre. The company
pays for up to ￡400 of accessories, of the salesmen’s own choice to be fitted to the cars and all of the running
costs, including private petrol. The cars are replaced every three years and the ‘old’ cars are sold at auction,
because they are high mileage vehicles.
The low emission cars it is proposed to purchase will have the same list price as the current cars, but the dealer
is only prepared to offer a bulk discount of 5% on these vehicles. Damian does not propose to make any other
changes to Linden Limited’s company car policy or practice.
Required:
(i) Explain the tax consequences of the proposed move to low emission vehicles for both the individual
salesmen and Linden Limited, illustrating your answer by means of relevant calculations of the tax and
national insurance (NIC) savings arising. (9 marks)
参考答案
正确答案：
(a) (i) Individual salesmen
The taxable benefit is determined by the list price of the vehicle plus the cost of the accessories (￡20,000) and the CO2
emission rate. The current vehicles have a CO2 emission rate of 168 grams/kilometre, so the benefit will be calculated
at the rate of 20% ((168 – 140)/5 + 15), resulting in a total annual car and car fuel benefit charge of ￡6,880 (20,000
x 20% + 14,400 x 20%). The low emission vehicles will be chargeable at the basic percentage rate of 15% resulting
in a total annual car and fuel benefit charge of ￡5,160 (20,000 x 15% + 14,400 x 15%). The salesmen will thus
make an annual income tax saving at their marginal rate of tax, i.e. ￡378 (1,720 x 22%) if they are basic rate taxpayers
and ￡688 (1,720 x 40%) if they are higher rate taxpayers.
Linden Limited
The current vehicles will be classed as ‘expensive’ cars based on the discounted list price plus the cost of the accessories
of ￡18,824 (19,600 x 94% + 400). The annual writing down allowances will thus be restricted to ￡3,000 throughout
the period of ownership, but there will be no restriction of the balancing allowance available on disposal. The low
emission vehicles will be eligible for a 100% first year allowance of ￡19,020 (19,600 x 95% + 400), but there will
also be a balancing charge on disposal equivalent to the sales proceeds. Therefore, the total of the allowances available
over the life of the cars will be effectively the same in both cases. As a single company with taxable profits of
￡1·4 million, Linden Limited will pay corporation tax at the small companies marginal rate of 32·75% in the year to
31 July 2007, giving a tax benefit in that year of ￡5,247 for each low emission car purchased ((19,020 – 3,000) x
32·75%).
The company will also make an annual saving in terms of the Class 1A national insurance contributions payable on the
salesmen’s benefits of ￡220 ((6,880 – 5,160) x 12·8%). But, as these Class 1A contributions are deductible for
corporation tax, the net saving will only be ￡205 (220 x (100 – 32·75)%).
As the VAT liability payable on the provision of private fuel is based on engine capacity (not the CO2 emission rate) this
will not necessarily be affected.