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HMRC v Mertrux Ltd

In HMRC v Mertrux Ltd (Upper Tribunal – 6 August) a company (M) had carried on a business of selling Mercedes cars. In 2003 it sold this business in return for consideration of £1 705 502. M claimed rollover relief on the basis that the gain arose from the disposal of its goodwill. HMRC disallowed 50% of the claim on the basis that only 50% of the consideration should be treated as attributable to goodwill and that 50% was compensation for the loss of M’s agreement with the car manufacturer which did not qualify for relief under TCGA 1992 s 155. M appealed. The First-tier Tribunal allowed the appeal but the Upper Tribunal reversed this decision and restored HMRC’s ruling. Newey J held that ‘the only possible finding’ was that part of the payment (described as a ‘territory release...

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