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Decision Number: |
TC 04273 |
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Appellant:
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Spring Capital Ltd |
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Respondent:
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1)The Commissioners for Her Majesty's Revenue & Customs
2)Roderick Thomas
3)Stuart Thomas
4)Spring Salmon & Seafoods Ltd |
Chairmen / Special
Commissioners: |
Guy BRANNAN
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Date Of Decision:
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10/02/2015 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Exemptions and reliefs |
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Notes:
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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
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Decision(s) to Download:
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TC04273.pdf 
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