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Digging up the playing field

29 September 2015 / Philip Ridgway
Issue: 4520 / Categories: Comment & Analysis
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Will the government and HMRC's attempts to level the goodwill playing field be effective?
KEY POINTS
 
  • Goodwill was included in the new intangible fixed asset regime from 2002.
  • The Balloon Promotions case and arguments over the exact nature of goodwill.
  • Under Finance Bill 2015/16 clause 32 amortisation will no longer be available for acquired goodwill.
  • Care will be required when considering claims to rollover gains from one intangible asset into others.
  • Arms’ length agreements on the allocation of a purchase price will be preferable to HMRC determinations.
 
The tax treatment of goodwill has had a chequered history. For many years it was subject to both capital gains tax and stamp duty. This changed in 2002 when for corporation tax purposes goodwill was included in the new intangible fixed asset...

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