Capital Gains Tax. Transfer of Headingley Cricket Stadium and whether attached ‘business’ or ‘income streams’. Whether goodwill existed, was capable of transfer and was in fact transferred.
Held: transfer of business with attached goodwill and not merely income streams. Importance of evidence and the value of opinions when looking at facts. IRC v Muller and Co’s Margarine Ltd [1901] AC 217, Ramsay v HMRC [2013] UKUT 226 (TCC), Kenmir v Frizzell and Others – [1968] 1 All ER 414 considered and applied. Balloon Promotions Ltd and others v Wilson (Inspector of Taxes) and another SpC 524 (2006) considered and approved.
Citations:
[2019] UKFTT 559 (TC)
Links:
Jurisdiction:
England and Wales
Capital Gains Tax
Updated: 26 October 2022; Ref: scu.641317
