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No relief for goodwill

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Revenue & Customs Brief 25/11 ‘affirms’ HMRC’s view that no corporation tax relief is due under the intangible fixed assets regime where a company has acquired a business that was carried on by a related party before April 2002, when the regime commenced.

HMRC have previously said they will challenge claims made on the basis that goodwill is created through synergies achieved on merging the business acquired with the existing business, and have now drawn attention a recent decision of the Upper Tribunal.

In Greenbank Holidays Ltd v HMRC, HMRC had rejected the taxpayer’s claim on the grounds that the goodwill had been created by the vendor company before 1 April 2002. The First-tier Tribunal dismissed the purchaser company’s appeal and the Upper Tribunal upheld that decision.