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Goodwill
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Goodwill
GOODWILL
Milton Park Holdings Ltd and another v HMRC
No entitlement to deductions for amortisation of purchased goodwill
The taxation of SMEs in 2023
David Whiscombe
Disputes over partnerships, goodwill, distributions and VAT were among some of this year’s key points of interest for SMEs, writes David Whiscombe (BKL).
Other cases that caught our eye 10 November 2023
Goodwill: M Smith and another v HMRC [2023] UKFTT 912 (TC) (30 October 2023) is an interesting case on the nature of goodwill. Two individual IFAs operated via a company. The business of the company was transferred to an LLP and the capital accounts...
Armstrong and Haire Ltd v HMRC
Goodwill following transfer of practices to company.
Landlinx, VAT and call options: HMRC’s famous public disaster
Chris Nyland
The treatment of call options had been considered settled for over 40 years, but HMRC now wishes to reimagine it. Chris Nyland (Gowling WLG) analyses the merits of HMRC’s logic and its actions.
Sale of goodwill
Peter Vaines
HMRC's views on goodwill and the sale of businesses were roundly rejected in a recent tribunal decision.
Professional goodwill
Peter Vaines
Some welcome clarity of the tax treatment of goodwill of a professional practice.
Intangible fixed assets: FA 2019 changes to goodwill and degrouping charges
Sarah Gabbai
Sarah Gabbai (McDermott Will & Emery) considers two important changes to the IFA regime introduced by the Finance Act 2019.
International briefing for September 2016
Tim Sarson
Tim Sarson (KPMG) takes over Chris Morgan’s long-running update on international issues. This month, Tim examines developments on BEPS, state aid and transfer pricing, among others.
Client connection: an elusive concept clarified
Nigel Doran
Nigel Doran (Macfarlanes) examines the recent decision in
HMRC v Smith & Williamson Corporate Services
on the taxation of payments in connection with the transfer of client connection to another business.
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3
EDITOR'S PICK
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
1 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
2 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
3 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
4 /7
The new Securities Transfer Tax: business as usual?
Georgina West
5 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
6 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
7 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
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VAT refund policy change for non-UK members of VAT groups
VAT on fund management services: new HMRC guidelines
Temporary zero rate for domestic electricity
CBAM admin regulations published
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J Scheckter v HMRC
Luxurico Ltd v HMRC
C Sagar v HMRC
Other cases that caught our eye: 18 September 2026
The Executors of Hunt and others v HMRC
IN BRIEF
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TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
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Grand Smile Design Ltd v HMRC
Raising standards without regulating the profession
Consultation tracker
The Executors of Hunt and others v HMRC
HMRC manual changes: 4 September 2026