Update - tax cases

Fishy business

S and R were partners of the S&R Partnership which dealt with seafood. Over 97% the partnership's purchases were from a company owned by S and R's family. Some 86% of its sales were to SS&S. B which was incorporated in the British Virgin Islands and administered in Guernsey owned all the shares in SS&S. B's shares were owned by a trust whose trustees were resident in Guernsey and the beneficiaries of which included S and R.
In July 2002 SS&S bought the entire S&R Partnership. The consideration was apportioned so that £2 800 000 was for the goodwill and £35 000 was for the partnership's stock. SS&S treated the goodwill as an intangible asset subject to relief under FA 2002 Sch 29 in its corporation tax self assessments for accounting periods ended 31 July 2002 and 2003.
In October 2004 HMRC opened...