Readers’ forum: Capital gains tax due on goodwill payment

Cecelia is 30 years old. She has lived with her parents all her life and seven years ago was made a partner in a small family business which has traded very successfully. Then Albert appeared. To cut a long story short Albert and Cecelia were married in the UK on 28 February 2023. On 3 March the couple left the UK for Barbados Albert’s home where he had a house waiting for his bride.

Meanwhile the partners decided to remove Cecelia from the partnership because they wanted to facilitate an incorporation. They instructed their solicitor to prepare a deed of retirement with an effective date of 15 March 2023 and a goodwill payment of £81 000 to Cecilia was agreed. There was no acquisition value so the whole of this payment represents a gain.

From my reading of the legislation Cecelia will become non-UK resident with effect...