Warning for partnership personnel changes? (Armour Veterinary Group v HMRC)

Table of contents

• What are the practical implications of this case?
• What was the background?
• What did the tribunal decide?
• The FTT’s other conclusions
• Court details:

Article summary

Tax analysis: In this decision, the First-tier Tax Tribunal (Tax Chamber) (FTT) dismissed an appeal against discovery assessments which disallowed amortisation relief claimed by the appellant company for three types of goodwill acquired from a partnership. The decision examined the applicability of each of the circumstances set out in section 882 of the Corporation Tax Act 2009 (CTA 2009) before concluding none of them had been satisfied. It also provided guidance on the meaning of carrying on a business pursuant to CTA 2009, s 884. Written by Helen McGhee, partner, and Megan Durnford, associate, at Joseph Hage Aaronson LLP.