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The taxpayer claimed that in September 2014 he sold goodwill which he owned personally to Dyer & Co Services Ltd a company of which he was a director and the majority shareholder for £1.2m.
He included employment income of £12 000 and a capital gain of £1.086m in his 2014-15 self assessment tax return. He claimed capital gains tax entrepreneurs’ relief on the disposal.
HMRC disagreed that the taxpayer owned any goodwill personally at the time of the purported sale. It amended his return to remove the gain and show employment income of £1.2m.
Between 1988 and 2003 the taxpayers carried on an accountancy business as a sole trader and then in partnership as Dyer & Co. In August 2003 he formed a new company Accountants Ltd of which he was the sole shareholder and director. He transferred the partnership to the company which...
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