UT upholds FTT decision on principles of valuation and allocation of consideration in acquisition of care homes
In Nellsar Ltd v HMRC [2025] UKUT 164 (TCC) (2 June) the Upper Tribunal (UT) dismissed both parties’ appeals and affirmed the decision of the First-tier Tribunal (FTT). In the context of acquiring care homes as a going concern the purchase price should on the basis of accounts compliant with generally accepted accounting principles (GAAP) be allocated to the care home properties using market value rather than depreciated replacement cost (DRC) for the purposes of corporation tax relief on amortisation of goodwill under the intangible fixed assets (IFA) regime and for the purposes of SDLT.
Nellsar had acquired five care homes as going concerns. For each acquisition Nellsar’s accounts allocated part of the purchase consideration to goodwill and part to freehold property on the basis of their DRC...
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UT upholds FTT decision on principles of valuation and allocation of consideration in acquisition of care homes
In Nellsar Ltd v HMRC [2025] UKUT 164 (TCC) (2 June) the Upper Tribunal (UT) dismissed both parties’ appeals and affirmed the decision of the First-tier Tribunal (FTT). In the context of acquiring care homes as a going concern the purchase price should on the basis of accounts compliant with generally accepted accounting principles (GAAP) be allocated to the care home properties using market value rather than depreciated replacement cost (DRC) for the purposes of corporation tax relief on amortisation of goodwill under the intangible fixed assets (IFA) regime and for the purposes of SDLT.
Nellsar had acquired five care homes as going concerns. For each acquisition Nellsar’s accounts allocated part of the purchase consideration to goodwill and part to freehold property on the basis of their DRC...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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