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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
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
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HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
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R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
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Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
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Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Apprenticeship Levy and Employment Allowance: new employer guidelines