[2025] UKUT 00164 (TCC) Nellsar Limited v The Commissioners for His Majesty's Revenue and Customs
Upper Tribunal Tax and Chancery decision of Mr Justice Mellor and Judge Brannan on 2 June 2025
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CORPORATION TAX 鈥搑elief for amortisation of goodwill 鈥� Schedule 29 Finance Act 2002 & Part 8 Corporation Tax Act 2009 鈥� purchase of care home businesses including properties 鈥� allocation of purchase price to goodwill (available for subsequent amortisation with corresponding corporation tax debits) and underlying real property鈥� UK GAAP 鈥� Financial Reporting Standards 6 & 7 鈥� RICS 鈥淩ed Book鈥� valuation principles 鈥� goodwill amounts dependent on property valuations 鈥� FTT concluded the properties should be fair valued under UK GAAP using market value rather than depreciated replacement cost 鈥� whether FTT鈥檚 conclusion open to it on the evidence 鈥� Edwards v Bairstow Stamp Duty Land Tax 鈥� just and reasonable apportionment of price paid for properties and for goodwill 鈥� paragraph 4, Schedule 4 Finance Act 2003