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Relief for goodwill
Key points
- To what point did the goodwill fall within the provisions of the intangibles regime?
- The court had to consider how the goodwill came about and the date of creation of goodwill as that date would determine whether relief was available.
- Who owns the goodwill in a partnership? Is it the individual partners or the partnership? What is the value of the goodwill?
- The Partnership Act 1890 applies by default. If you don’t want its provisions to apply it must be specifically ruled out.
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 ...
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