Disposal of partnership assets over long period

In 1970 the taxpayer became a partner in an accounting firm. In 1996 he started to consider retirement and identified two new partners suitable to take over from him. It was agreed that the new partners would pay the taxpayer £20 000 a year for the £434 000 work in progress until he was left with a token 1%. He would transfer clients which would reduce his profit share and he would reduce his hours to match.

By 2017-18 the taxpayer had disposed of 99% of the goodwill and old work in progress. He was entitled to 20% of the partnership profits which was reduced by 8% during the year. The transfer took longer than anticipated for various reasons but by 2021 he had handed over all his clients.

In October 2017 the partnership sold its office premises to the taxpayer’s pension scheme which then rented it...