New queries, issue 4629

Tax toothache

Can HMRC open an enquiry into a previously agreed goodwill figure?

A Northern Ireland dentist incorporated his practice in June 2010. There is an equal mix of NHS and private clients and based on previous results goodwill was valued at £900 000. In November 2012 HMRC queried this under TMA 1970  s 9A and to avoid costs our client accepted HMRC’s reduced figure of £600 000. The enquiry was formally closed under TMA 1970 s 28A(1) and (2) in June 2013.

In August and September 2014 HMRC opened aspect enquiries into the company return for the year ended 30 April 2013 and the client’s 2013 personal tax return. The company enquiry concerned the turnover split between NHS and private work and the personal one concerned the recording of NHS income. It then transpired that in Scotland and Northern Ireland...