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Spring Capital Ltd (TC5382)
Reasonable grounds for believing tax was overcharged
The taxpayer applied for the postponement of corporation tax of £516 721. It had arisen as a result of a consequential amendment by HMRC disallowing a claim for intangibles relief of £2m. The relief related to the amortisation of goodwill acquired by the taxpayer on the transfer of the business to it from Spring Salmon & Seafood Ltd.
In essence HMRC refused the claim because in an earlier First-tier Tribunal decision (TC4273) concerning the goodwill the judge had concluded that the company was not entitled to relief. HMRC interpreted this as implying the judge had given consideration to FA 2002 Sch 29 para 92 (transfers between company and related party treated as being at market value) and para 118 (application of the schedule to assets created or...
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