Transfer of business:In 2 Green Smile v HMRC [2023] UKFTT 15 (TC) (20 December 2022) the issue was the timing of the transfer of business from a partnership to a company. The date was important both for determining who was responsible for tax on the income but also whether or not the company was able to obtain relief for the cost of the goodwill it acquired. The facts were however far from straightforward and there was some significant confusion over exactly what had happened and when. But ultimately the judge found that there was enough evidence to support the date on which the taxpayers had said the transfer had happened. The assessments raised by HMRC were cancelled. While the decision is very much one on the facts there is a lot here which of interest when looking at what precisely needs to be done in order...
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Transfer of business:In 2 Green Smile v HMRC [2023] UKFTT 15 (TC) (20 December 2022) the issue was the timing of the transfer of business from a partnership to a company. The date was important both for determining who was responsible for tax on the income but also whether or not the company was able to obtain relief for the cost of the goodwill it acquired. The facts were however far from straightforward and there was some significant confusion over exactly what had happened and when. But ultimately the judge found that there was enough evidence to support the date on which the taxpayers had said the transfer had happened. The assessments raised by HMRC were cancelled. While the decision is very much one on the facts there is a lot here which of interest when looking at what precisely needs to be done in order...
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