Chemidex Generics Ltd v HMRC

In Chemidex Generics Ltd v HMRC [2024] UKFTT 1146 (TC) (19 December 2024) the FTT held that the taxpayer’s valuation of intellectual property (IP) acquired by a related party was within a justifiable range and its decision to amortise the IP over ten years was UK GAAP compliant. 

Chemidex Generics Ltd (CGL) acquired IP relating to certain out-of-patent pharmaceutical products and related assets such as marketing authorisations (the ‘product assets’) from a partnership formed by Mr Navin Engineer and Mrs Varsha Engineer (together ‘the partners’). In most cases the partners had entered into profit sharing agreements (PSAs) with a company Chemidex Pharma Ltd (CPL) which was wholly owned by them as was CGL. Those PSAs granted CPL the right to exploit the product assets. Following the transfer CGL owned the product assets and held the...