Amortisation of goodwill: Although Armour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC) (13 June) is a case about corporation tax relief for the amortisation of goodwill it will be of more interest to partnership practitioners. This is because the availability of the relief was dependent on the date on which the partnership goodwill which was acquired by the company came into existence. That in turn depended on the date on which one of the individuals involved became a partner. He was described as a salaried partner but there was a dispute over whether this meant that he was actually a partner or as the taxpayer argued this was no more than some sort of courtesy title for somebody who was on a fixed profit share. The facts are quite complex but what is likely to be of interest is the discussion at para 112 onwards on whether...
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Amortisation of goodwill: Although Armour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC) (13 June) is a case about corporation tax relief for the amortisation of goodwill it will be of more interest to partnership practitioners. This is because the availability of the relief was dependent on the date on which the partnership goodwill which was acquired by the company came into existence. That in turn depended on the date on which one of the individuals involved became a partner. He was described as a salaried partner but there was a dispute over whether this meant that he was actually a partner or as the taxpayer argued this was no more than some sort of courtesy title for somebody who was on a fixed profit share. The facts are quite complex but what is likely to be of interest is the discussion at para 112 onwards on whether...
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