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Spring Capital Ltd (TC4273)
The taxpayer company acquired a trade from an associated company and claimed loss relief under CTA 2010, s 940A to s 953.
HMRC refused on the ground the common ownership test had not been met.
The taxpayer appealed, being also in dispute with the Revenue about the amortisation of goodwill.
The First-tier Tribunal allowed the claim for loss relief in principle, subject to quantification of figures, and adjourned the appeal pending the determination of another by the company.
But the tribunal held there had been no purchase of goodwill, meaning the taxpayer was not entitled to the deduction it had claimed for amortisation.
The appeal was one of several by the taxpayer and its associated company. Many are listed in the appendix to the First-tier Tribunal in Spring Salmon & Seafood (TC4002).
