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The outcome of this case may be the stuff of legends. A taxpayer takes his case to the First-tier Tribunal (FTT) to argue that the disposal of his business gives rise to a capital gains tax liability of £1.4m and not a distribution which would give rise to an income tax liability of £2m. He leaves the tribunal with no tax liability at all having extracted £8.25m tax-free from the company that he indirectly controls. The only cloud is that the company was denied relief for the amortisation of the £8.25m spent on the goodwill it acquired.
This is the decision of the tribunal in Jasper Conran (TC8391) handed down on 3 February 2022 by Judge Zaman in which Mr Conran’s appeal was allowed and JC Vision Ltd’s appeal was denied.
Background
The facts are complicated but concern the effective incorporation of the business of a limited liability partnership...
