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No goodwill here

04 February 2014 / Pete Miller
Issue: 4438 / Categories: Comment & Analysis , Companies

The rejection by the First-tier Tribunal of the taxpayer’s claim in Armajaro Holdings Ltd


  • Corporate member of an LLP claims relief for goodwill acquired from other individual partners.
  • Assets acquired by a corporate member were partnership rights not goodwill.
  • Entity level accounts did not recognise goodwill or include amortisation.
  • Does CTA 2009 s 1273 allow an amortisation claim?
  • Tribunal held that s 1273 did not override accounting treatment.

The regime for the taxation of intangible fixed assets of companies was introduced by FA 2002 from 1 April 2002; originally in FA 2002 Sch 29 it is now in CTA 2009 Part 8.

This is an exclusive regime meaning that Part 8 is the only legislation determining the amounts brought into account for corporation tax purposes. It is of course subject to any...

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