Unpicking the Finance Bill 2015—restricting relief for incorporations

Table of contents

• Original news
• What did the government announce in these two related measures?
• Did this come as a complete surprise, and what was the thinking behind it?
• In view of the high cost of entrepreneurs' relief to the Exchequer, do you expect more curtailments to this relief in future?
• The draft intangibles legislation applies the new rules to goodwill, and intangibles associated with goodwill, do you think it will be straightforward in practice to identify which assets are caught?
• What will be the likely impact of these two changes, and how should lawyers be advising their clients?

Article summary

Tax analysis: The Autumn Statement 2014 included changes to the tax treatment of transfers of goodwill to affiliated companies upon incorporation. Jolyon Maugham of Devereux Chambers explains the new provisions that are intended to snuff out a tax planning device that HMRC clearly envisaged would grow to costly proportions.