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SDLT and Goodwill

 
Patrick Cannon considers what effect the recent alterations in HMRC's Capital Gains Tax Manual might have on SDLT reporting and payment in relation to goodwill
 
Taxpayers who check the box at the start of the SDLT 4 return to confirm that the land transaction is part of the sale of a business that includes goodwill can normally expect to receive an enquiry letter. That letter will ask whether SDLT was paid on the goodwill element of the amount of the total price identified in the SDLT 4 and refer the reader to what is said about goodwill in the HMRC Capital Gains Tax Manual.
 
If the taxpayer has not paid SDLT on the goodwill letters will usually be exchanged between the taxpayer's advisers and HMRC debating whether some or all of the...

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