Tax relief for goodwill: Armour Veterinary Group Ltd

The First-tier decision in the Armour case (Armour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC)) was a win for HMRC. The headline issue was tax relief for goodwill and more precisely relief under the corporate intangibles regime for related party goodwill. But the case has much wider relevance bearing on the conduct of partnership businesses generally as well as partnership incorporation.

Doing the impossible

There are times when the only appropriate reaction to the workings of the First-tier Tribunal is admiration. Faced with the legal equivalent of a teenager’s bedroom it calmly takes stock tidies the facts into drawers suggests new possibilities and lays everything neatly out beside the legislation.

What it’s all about

The case was brought by a company operating a veterinary practice which had claimed a deduction for goodwill in its accounts. The central...