Entrepreneurs’ Relief and Goodwill – what did the Autumn Statement say?

 CGT, Corporate Tax, IP Tax  Comments Off on Entrepreneurs’ Relief and Goodwill – what did the Autumn Statement say?
Jan 252015

Updated July 2015

This article was updated just days before the Summer Budget which took place on 8 July 2015. It is now the case that a company acquiring a business will no longer be able to claim tax relief on goodwill being amortised in the accounts. This is irrespective of whether the business was acquired from a related party. 

In this article we are going to take a closer look at the new rules which seek to restrict tax relief for goodwill when a business is sold. These restrictions were announced in the recent Autumn Statement,  and have since become law, being incorporated into the first Finance Act of 2015. The new rules  are aimed at individuals or partnerships who decide to incorporate their business. What is striking is that the new rules go further than the mischief that they are intended to counteract. Continue reading »

Jan 182015

Updated January 2016

In the case of Drilling Global Consultant LLP v HMRC, a limited liability partnership (“LLP”) was denied the annual investment allowance on upgrading an aircraft on the basis that its members weren’t all individuals. The result is a straightforward application of the capital allowances legislation. However, the arguments put forward by the LLP are of some interest, as well as being totally wrong.

(This article can be downloaded in pdf format at Academia.edu.)

Continue reading »

Jan 042015

I would like to take the opportunity of the first post of 2015 to wish my readers a Happy New Year and a big thank you for your support in reading the articles on this site.

In particular I would like to say a special thank you to Alain Thielemans and Malgorzata Gergelewicz, co-founders of International Tax Plaza, for their strong support over the last year. Alain, Malgorzata and I met via linkedin and our friendship started when Alain wrote to me to say how much they enjoyed reading my articles. Continue reading »