In N Dyer v HMRC [2020] UKFTT 72 (TC) (10 February) the First-tier Tribunal upheld an assessment on the basis that a payment of £1.2m made by a company to its principal shareholder was earnings and not as he contended a payment to acquire the goodwill of a business.
Mr Dyer was a chartered accountant who had been in practice since 1988. He had initially operated as a sole trader but subsequently operated in partnership and from 2003 through a company ‘Accountants’ then wholly owned by him. In 2007 ‘Accountants’ was put into liquidation and the business transferred to another company ‘Services’. In 2014 Services approved a payment to Mr Dyer of £1.2m.
Mr Dyer contended that the payment was for the sale by him to the company of the goodwill of the business it carried on and claimed (under the rules...
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