Technical articles

Advanced Taxation (ATX) was previously known as P6 Advanced Taxation. All exam resources listed as P6 can be used for studying ATX.

Advanced Taxation United Kingdom (ATX-UK)

Finance Act 2020
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article summarises the changes made by the UK Finance Act 2020. 

Summary of available articles
An overview and synopses of the latest technical articles to support you in your studies.

Corporation tax 
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article considers the taxation of a company as it begins trading, acquires an additional business, and eventually invests overseas. It sets out the commercial decisions taken by the company and its shareholders at the different stages in the company’s development and summarises the tax implications of those decisions.

Corporation tax – groups and chargeable gains 
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article begins by briefly summarising the rules relating to both group relief groups and capital gains groups. It then goes on to consider various issues relating to capital gains groups that could be introduced in an exam question. It does not include comprehensive explanations of the rules but assumes a reasonable knowledge.

Corporation tax – group relief 
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article begins by briefly summarising the rules relating to both group relief groups and capital gains groups. It then goes on to consider a number of group relief tax planning issues that could be introduced in an exam question. It does not include comprehensive explanations of the rules but assumes a reasonable knowledge.

Inheritance tax and capital gains tax
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article considers the occasions where both capital gains and inheritance taxes are relevant to a transaction. It also features illustrations of some issues that need to be considered when giving advice in the context of the exam.

International aspects of personal taxation
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article begins with some basic rules, an understanding of which enables the particular areas of tax affected by an individual coming to, or leaving, the UK to be identified. It then goes on to review those areas in some detail, and provides a clear set of questions to ask in order to determine an individual’s liability to UK taxes. Finally, it deals briefly with the impact of double tax relief and treaties.

Taxation of the unincorporated business
The new business
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article looks at the issues relating to a new business including the choice of business vehicle and the first years of trading.

Taxation of the unincorporated business
The existing business
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article looks covers some of the issues relating to extraction of profits, change of accounting date and the final years of a business.

Trusts and tax
Relevant to those sitting ATX-UK in June, September or December 2021 or March 2022
This article has been written because the taxation of trusts and the transfers of assets to and from trustees is a complicated area of the UK tax system. Accordingly, there is a need to set out the rules that may be examined and those areas where knowledge is not required. 

Advanced Taxation - other variants

ATAD controlled foreign company rules
Relevant to ATX-MLA
During 2018, Malta transposed into Maltese tax legislation the provisions of Council Directive 2016/1164 issued on 12 July 2016 (commonly referred to as Anti-Tax Avoidance Directive, ATAD I). Some of the provisions of ATAD I and II are included in the ATX-MLA syllabus and are examinable from June 2020 onwards. The first article in a three-part series explains the controlled foreign company (CFC) rules.

ATAD GAAR and exit tax rules
Relevant to ATX-MLA
The three-part series continues with an explanation of the general anti-abuse rules (GAAR) and exit tax.

ATAD interest limitation rules
Relevant to ATX-MLA
The three-part series concludes with an explanation of the interest limitation rules.

Consolidated group rules 
Relevant to ATX-MLA
This article explains the main provisions of the Consolidated Group (Income Tax) Rules and with a view to guiding ATX-MLA candidates in respect of the examining team’s expectations on the topic

VAT treatment of call-off stock
Relevant to ATX-MLA
The VAT treatment of call-off stock is included in the ATX-MLA syllabus and is examinable from June 2021 onwards.

Transitioning into sales tax and service tax – clarifying the confusion
Relevant to ATX-MYS
The article is relevant for candidates preparing for FTX-MYS Foundations in Taxation as well as providing a good foundational read for candidates taking the TX (MYS) and ATX (MYS) exams. The article is based on prevailing laws as at 31 March 2019.

Key Budget 2020 proposed tax changes
Relevant to ATX-SGP
This article focuses on the specific tax measures that were introduced in the main Singapore Budget 2020.

Advanced aspects of service tax – management services
Relevant to ATX-MYS
This article addresses the advanced aspects of service tax in relation to the provision of management services.

Real Property Gains Tax
Relevant to ATX-MYS
This three-part article discusses the provisions relating to the general aspects of the Real Property Gains Tax Act 1976 (RPGT Act) as at 31 March 2019. It also looks at the provisions in the act that directly impact the RPGT liability, as well as compliance requirements, and provisions relating to special aspects.

Labuan: a comprehensive look (updated)
Relevant to ATX-MYS
This article aims to pull together various laws and successive development in the relevant laws relating to entities in Labuan, an island in the South China Sea established in 1990 as an international offshore financial centre (IOFC) and rebranded in recent years as an international business financial centre (IBFC).

Notional interest deduction (NID) rules
Relevant to TX-MLA and ATX-MLA 
During 2017, Malta introduced a new NID regime, which is effective from the 2018 year of assessment. The NID is designed to align the tax treatment of the cost of equity with that of the cost of debt. 

The Spice Girls
Relevant to ATX-IRL
Residency rules are many and complex. Tax lecturer Paula Byrne illustrates some of the intricacies of these rules with a little help from her favourite girl band.

Recent changes to the stamp duty regime in Singapore
Relevant to ATX-SGP
The stamp duty regime in Singapore has undergone some significant changes in recent years and this article takes stock of these changes.

Key Budget proposed tax changes for businesses
Relevant to ATX-SGP
Singapore's finance minister delivered a futuristic Budget statement for the Financial Year 2018 (Budget 2018) in February 2018. This article highlights the significant tax changes announced for businesses.

Tax incentives for research and development in Malaysia
Relevant to ATX-MYS
This article collates and discusses the provisions in the Income Tax Act 1967 (the Act) and the Promotion of Investments Act 1986 (PIA) to promote candidates' understanding of the interplay of the income and deductions relating to the various R&D activities or expenditure. While reading this article, candidates are expected to refer to the relevant provisions of the Act, the PIA, and Public Ruling 5 of 2004 as amended in 2008.

Pioneer status, investment tax allowance, and reinvestment allowance
Relevant to ATX-MYS
This article collates and discusses the provisions in the Income Tax Act 1967, and the Promotion of Investments Act 1986 (PIA). While reading this article, candidates are expected to refer to the relevant provisions of the Act and PIA, as amended.

Tax treatment of interest income and interest expense
Relevant to ATX-MYS
This article collates and discusses the provisions in the Income Tax Act 1967 to assist candidates with understanding the more intricate issues relating to interest income and interest expense. While reading this article, candidates are expected to refer where necessary to the relevant provisions of the Act and the Public Ruling 9 of 2015.

The pitfalls of interest deduction claims by corporate taxpayers
Relevant to TX-HKG and ATX-HKG
This article is relevant to candidates preparing to sit TX-HKG and ATX-HKG. It aims to explain, in layman terms as far as possible, the Hong Kong tax rules and practice surrounding the claims for interest deductions by corporate taxpayers. It should be read in conjunction with The pitfalls of interest deduction claims by individual taxpayers.

Investment incentives
Relevant to ATX-MYS
This article focuses on sections A1(g) and A2(c) of the syllabus, with a discussion of the key points and highlighting areas worth noting, comparing and contrasting, where relevant.

Miscellaneous receipts
Relevant to ATX-MYS
This article is relevant to section A3 of the syllabus, the nature and taxability of miscellaneous receipts including sums arising on disposal of, or otherwise dealing with, tangible and intangible assets, grants, subsidies, donations and contributions, awards, scholarships, and gifts and inheritances.

Anti-avoidance provisions in Malaysia
Relevant to ATX-MYS
This article is an updated version of the article published in November 2011. It is relevant to candidates preparing for ATX-MYS and the laws referred to are those in force at 31 March 2021. It discusses only the provisions in the Income Tax Act 1967 (the Act). 

Employee share schemes
Relevant to ATX-MYS
The purpose of this article is to discuss the Malaysian income tax implications arising from the provision of employee share schemes, focusing on Employee Share Option Schemes and Employee Share Purchase Plans.

Basis periods
Relevant to ATX-MYS
The focus of this article is the determination of basis periods for a company on the commencement of operations and when there is a change of accounting date.

Taxation of individuals – advanced aspects
Relevant to ATX-MYS
This article has been updated to prevailing tax laws as at 31 March 2016. 

The pitfalls of interest deduction claims by individual taxpayers
Relevant to TX-HKG and ATX-HKG
This article is relevant to candidates preparing to sit TX-HKG and ATX-HKG. It aims to explain, in layman terms as far as possible, the Hong Kong tax rules and practice surrounding the claims for interest deductions by individual taxpayers.

Share-based remuneration
Relevant to ATX-IRL
Share-based remuneration schemes are used by employers – mainly public companies – to reward employees and ensure their continued commitment. This article explains the tax treatment of four different types of share-based remuneration and is relevant to candidates preparing to sit the ATX-IRL exam.

Taxation of trusts in Malaysia
Relevant to ATX-MYS
A comprehensive focus on the taxation of trusts in Malaysia, including an outline on what trusts are, aspects of tax treatment of trusts and trust beneficiaries, and tax computation of trusts.

Understanding the four-year rule for dividends between Cyprus tax resident companies 
Relevant to ATX-CYP
This article considers the tax treatment of the four-year rule which, when applied, does not allow for the exemption from the imposition of special defence contribution (SDC) on dividends between Cyprus tax-resident companies.

Back-to-back loans
Relevant to ATX-CYP
This article explains the tax treatment of back-to-back loans, as well as an amendment relating to the deductibility of loan interest when the loan is used to purchase shares in a 100% subsidiary of a Cyprus company.

Double tax agreements
Relevant to ATX-MYS
The main features of double tax agreements and an explanation of some common terms and catchphrases used in connection with treaties.

Revenue audit
Relevant to ATX-IRL
This article is based on the Revenue Audit Code of Practice 2010, which is effective from 1 October 2010 and is relevant for students sitting ATX-IRL from June 2012 onwards.

The export incentive regime in Malaysia
Relevant to ATX-MYS
An overview of the prevailing export incentives regime in Malaysia.

The taxation of trusts
Relevant to ATX-IRL
This article is based on current tax legislation inclusive of the Finance Act 2009 and relevant for ATX (IRL) candidates.

Study support videos

Capital gains tax
Steve Singleton from Kaplan Financial outlines how to approach capital gains tax questions in a P6 (UK) exam using previous exam questions as examples.
Cannot access Youtube? Watch it here

Advice for students retaking exams
This video is about turning your exam fail into a pass at your next attempt. It suggests ways to reflect on where you went wrong, how to draw up an effective study plan, and practising exam questions.

Syllabus updates

Amendments to the P6 (CYP) syllabus
As a result of austerity measures, actions to combat fraud as well as measures aiming to promote business, there are significant amendments to tax legislation and consequently to the syllabus for the 2013 sittings. In addition, there are changes to the format of the paper. This article explains these changes and amendments.

Exam technique

Stepping up from TX (UK) to ATX (UK)
This article identifies the knowledge you need to bring from your TX studies to be successful in ATX.

Stepping up from TX (CYP) to ATX (CYP)
ATX (CYP) is directly underpinned by TX (CYP). Knowledge and understanding of the technical content of TX (CYP) is therefore vital for candidates to be successful at ATX (CYP).

Stepping up from TX (IRL) to ATX (IRL)
ATX (IRL) is directly underpinned by TX (IRL). Knowledge and understanding of the technical content of TX (IRL) is, therefore, vital if candidates are to be successful at ATX (IRL).

How to approach Advanced Taxation
To study Advanced Taxation effectively you need to understand the nature of the exam and what you will be asked to do.

Passing Strategic Professional exams
This article looks at what you can do to improve your chances of passing ACCA’s Strategic Professional exams.

P6 – A guide to using the examiner’s reports
Guidance to help you if you are taking the P6 exam for the first time as this takes you through how to use the examiner’s reports as part of your revision phase as directed by the study-support guides. This document will help you to understand how you should be using the examiner’s reports to make the best use of them.

P6 – A guide to reflection for retake students
Guidance to help you if you are retaking the P6 exam as this takes you through the process of reflection using the examiner’s reports as directed in the retake guides. This document will help you to understand how you should be using the examiner’s reports to make the best use of them.

Passing the ATX (UK) exam
This article sets out the two issues which are relevant to success in the ATX (UK) exam: technical knowledge and exam technique.

Preparing for success in the P6 (MLA) exam
Useful tips for candidates planning to take P6 (MLA).

Examiner's approach to P6 (MYS)
This article provides guidance on a new style of question within Section A from the December 2014 sitting of P6 (MYS) and also provides some advice on good exam technique and best exam practice.

Examiner's approach to P6 (UK) – updated
The aim of the exam, its structure and format.

Exam technique and fundamental technical issues
This article outlines two important aspects of examination technique and a number of fundamental technical areas that need to be mastered. This article is relevant to students who are beginning their studies and also those for whom the exam is imminent.

Guidance on answering Section A questions for P6 (UK)
An outline of some key advice for students on answering the two questions in Section A of P6 (UK).

Improving your performance
This article, which is relevant to all those preparing to sit P6 (UK), looks at the four aspects of exam technique: reading the question, satisfying the requirements, thinking, and time management. It also provides an overview of useful P6 (UK) technical articles.

How to earn professional marks
This article explains what professional marks are, how they are awarded at the Strategic Professional level and to remind potential candidates how best to achieve these additional, and often crucial, marks.

Exam support resources

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