NO.PZ202304050100008502
问题如下：
(2) Eriksson mentions that Trana is undertaking a comprehensive review of its operations in 2016, and its objectives include reducing overall tax costs by lowering its effective tax rate and reducing foreign exchange gains and losses reported on the income statement.
Which of the following strategies would be most likely to help Trana achieve at least one of the objectives mentioned by Eriksson for 2016?
选项：
A.
Raise the price at which Anart sells its goods to other group members
B.
Increase the number of stores in the US region
C.
Initiate a hedge on the net asset position of the eurozone subsidiary
解释：
A is correct. Anart operates in a South American country with the lowest tax rate of the group—10% versus 25% in the United States, 30% in the eurozone, and 22% (or 16.5%) in Sweden. If more of the corporate profits are earned by Anart, the effective tax rate will decrease.
Anart currently earns a return of 204/4,485 = 4.5%, whereas the overall corporate profit rate is 10.3% (3,096/30,200).
Any income taxed in South America would be eligible for a tax credit in Sweden, and Trana would be liable for the tax difference between the local 10% rate and the rate in Sweden (22% or 16.5%).
To the extent that taxable income can be diverted from the US or eurozone operations (where the rates are higher than Sweden’s), it would result in an overall tax saving for Trana.
By increasing the price at which Anart sells goods to the US and eurozone subsidiaries, it would increase the taxable income earned in South America and reduce the taxable income (through higher cost of goods sold) in the United States and the eurozone. Because of the tax treaty with Sweden, there would be no net tax savings on the goods sold to US and eurozone stores by Anart if the prices change.
Because both retail subsidiaries are translated using the current rate method, all foreign exchange gains/losses are reported in other comprehensive income not on the income statement. Therefore, the effects of hedging the exposure in the Eurozone subsidiary would also be reported in other comprehensive income and not affect the income statement. Increasing the number of stores in the US would increase the amount of income in the highest tax jurisdiction and hence increase taxes, not lower them.
B is incorrect. Increasing the number of stores in the US region will not affect the tax rate, but would increase taxable income because the tax rate there is greater than in Sweden and would not affect foreign exchange gains and losses on the income statement because it is self-sustaining, and the gains and losses go to other comprehensive income.
C is incorrect. The eurozone subsidiary is also self-sustaining, and any effect of hedging its net asset position would go to other comprehensive income, not net income. The eurozone’s taxes are higher than in Sweden, so there would be no lowering of taxes either.
请问我对于C选项的理解是否正确：
T公司要对冲对于Euro Zone子公司的net asset expo，以此来降低unrealized gain on Fx。但因为是current rate method，这一项是在OCI列示，不会影响利润表所以也就不会影响税收。
但即使是使用了temporal method，这一项不是在net income before g/l on Fx之后吗？所以也不会影响到税收？
