FTTTx CORPORATION TAX – deductions for amortisation of goodwill – Schedule 29 FA 2002 – whether goodwill purchased on a transfer of trade in September 2004 or whether a migration of trade – market value of goodwill – principles for determining market value of goodwill on transfer of trade – whether a transfer of trading losses to the appellant under section 343 ICTA 1988 – whether quantum of trading losses can be disputed – effect of undertaking given by HMRC to the Court of Session in other proceedings- construction and effect of the undertaking – Contracts (Third Parties) Act 1999 – whether valid consequential amendment to return to 2008 return under paragraph 34 Schedule 18 FA 1998 – whether valid claims for relief for the purposes of paragraph 51 Schedule 18 FA 1998 – appeals dismissed in relation to deductions for amortisation of goodwill – issue of quantum of losses under section 343 ICTA 1988 adjourned pending outcome of separate appeal by predecessor company
[2015] UKFTT 66 (TC)
Bailii
Contracts (Third Parties) Act 1999
England and Wales
Corporation Tax
Updated: 28 December 2021; Ref: scu.543227