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Wrong answer
Key points
- Chris Thomson progressively sold his 99.9% share in an accountancy business to two partners.
- The assets of the practice comprised premises goodwill and work in progress with debtors.
- ER was claimed on the sale of the business property to Chris’ pension fund.
- HMRC incorrectly refused the claim to ER claiming that it was not a qualifying associated disposal despite Chris Thomson’s explanations.
- HMRC’s decision was upheld for different – incorrect – reasons at statutory review.
- The FTT’s decision was that the disposal was part and parcel of a wider disposal and ER was available.
Every now and then a tax case decision comes along which looks fairly innocuous until you start looking into it in more detail. Such a case is that of Christopher Thomson (TC8337). I should note a prior interest in this case which started when I responded to a Readers’ Forum question number 19520 in...
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