In Armstrong and Haire Ltd v HMRC [2020] UKFTT 296 (TC) (17 July 2020) the FTT dismissed the company’s appeal against a decision not to allow deductions for the amortisation of goodwill under the intangible fixed assets regime.
In 2010 two individual dentists merged their practices by forming a company of which they became the sole shareholders and directors and transferring the businesses to the company. The businesses had originally been acquired by the dentists in 1996. The company claimed deductions in respect of the amortisation of goodwill. HMRC disallowed the deductions on the basis that the goodwill had been acquired from a related party that had carried on the same business prior to 1 April 2002 so that the goodwill was excluded from the intangible assets rules by CTA 2009 s 882(1).
The company argued however that CTA 2009 s 884 treated goodwill...
