Commentary

C3.1501 Introduction

Capital gains tax
Capital gains tax | Commentary

C3.1501 Introduction

Capital gains tax | Commentary

Division C3.15     Goodwill and intellectual property rights

For updates affecting this Division please see Part C0 Updates

CGT treatment of goodwill and intellectual property rights

C3.1501 Introduction

Goodwill, which is an asset within the meaning of TCGA 1992, s 21(1)1, is not defined for capital gains tax purposes. HMRC refer to the decision in Balloon Promotions Ltd v Wilson; Vela-Castro & Ors v Rodin2 which provides authority that for capital gains tax purposes goodwill should be construed in accordance with legal rather than accountancy principles3. The leading legal authority is given in a stamp duty case4 which held that goodwill is

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