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The rejection by the First-tier Tribunal of the taxpayer’s claim in Armajaro Holdings Ltd
KEY POINTS
- Corporate member of an LLP claims relief for goodwill acquired from other individual partners.
- Assets acquired by a corporate member were partnership rights not goodwill.
- Entity level accounts did not recognise goodwill or include amortisation.
- Does CTA 2009 s 1273 allow an amortisation claim?
- Tribunal held that s 1273 did not override accounting treatment.
The regime for the taxation of intangible fixed assets of companies was introduced by FA 2002 from 1 April 2002; originally in FA 2002 Sch 29 it is now in CTA 2009 Part 8.
This is an exclusive regime meaning that Part 8 is the only legislation determining the amounts brought into account for corporation tax purposes. It is of course subject to any indications...
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