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Goodwill
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Goodwill
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.
Practical problems with hive downs
Jeremy Webster
Jeremy Webster (Pinsent Masons) answers a query on a sale of a business by way of hive down and subsequent share sale.
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EDITOR'S PICK
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
1 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
2 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
3 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
4 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
5 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
6 /7
2024: that was the year that was
Jemma Dick
7 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
NEWS
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HMRC manual changes: 21 February 2025
HMRC launch e-invoicing consultation
NICs relief in special tax sites: postcode requirement introduced
Company size thresholds apply for off-payroll working rules
Paying voluntary NICs when abroad
CASES
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A Taxpayer v HMRC
HMRC v Royal Bank of Canada
R (oao) Anglia Ruskin Students’ Union v HMRC
B Joseph v HMRC
Lloyds Asset Leasing Ltd v HMRC
IN BRIEF
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Salaried members update
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
MOST READ
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Salaried members: HMRC reverses position on the TAAR and Condition C
Lloyds Asset Leasing Ltd v HMRC
Salaried members update
US ‘rejects very nature’ of UN tax talks
Mersey Docks: you’re my wonderwall