Decision Number: | TC 08908 |
Appellant: | NELLSAR LIMITED |
Respondent: | His Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Kevin POOLE |
Date Of Decision: | 11/08/2023 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | Corporation tax - relief for amortisation of goodwill - Schedule 29 Finance Act 2002 & Part 8 Corporation Tax Act 2009 - purchase of care home businesses including properties - amounts of goodwill to be recognised and capitalised on acquisition, available for subsequent amortisation with corresponding corporation tax debits - UK GAAP - Financial Reporting Standards 6 & 7 - RICS -Red Book- valuation principles - goodwill amounts dependent on property valuations - whether properties should be fair valued under UK GAAP using market value or depreciated replacement cost Stamp Duty Land Tax - just and reasonable apportionment of price paid for properties and for goodwill - paragraph 4, Schedule 4 Finance Act 2003 |