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Tax

15 November 2013
Issue: 7584 / Categories: Case law , Law digest , In Court
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Armajaro Holdings Ltd v Revenue and Customs Commissioners [2013] UKFTT 571 (TC), [2013] All ER (D) 41 (Nov)

Schedule 29 to the Finance Act 2002 applied to goodwill as it applied to an intangible fixed asset. Goodwill in Sch 29 had the same meaning as it had for accounting purposes. Intangible fixed asset was defined by para 2(1) of Sch 29 in relation to a company but not in relation to a partnership or LLP. Entitlement to relief under Sch 29 to the 2002 Act was dependent on the expenditure being reflected in the accounts of the company claiming entitlement to relief. The accounts had to be drawn up in compliance with UK GAAP. Relief under Pt 2 of Sch 29 was given by reference to expenditure written off or written down for accounting purposes. If accounting rules or practice did not permit the expenditure on acquiring an interest in an LLP to be treated as the acquisition of the LLP’s intangible fixed assets included then s 118ZA of the Income and Corporation Taxes Act 1988 did not change the accounting rules or

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MOVERS & SHAKERS

Pillsbury—Lord Garnier KC

Pillsbury—Lord Garnier KC

Appointment of former Solicitor General bolsters corporate investigations and white collar practice

Hall & Wilcox—Nigel Clark

Hall & Wilcox—Nigel Clark

Firm strengthens international strategy with hire of global relations consultant

Slater Heelis—Sylviane Kokouendo & Shazia Ashraf

Slater Heelis—Sylviane Kokouendo & Shazia Ashraf

Partner and associate join employment practice

NEWS
The government’s plan to introduce a Single Professional Services Supervisor could erode vital legal-sector expertise, warns Mark Evans, president of the Law Society of England and Wales, in NLJ this week
Writing in NLJ this week, Jonathan Fisher KC of Red Lion Chambers argues that the ‘failure to prevent’ model of corporate criminal responsibility—covering bribery, tax evasion, and fraud—should be embraced, not resisted
Professor Graham Zellick KC argues in NLJ this week that, despite Buckingham Palace’s statement stripping Andrew Mountbatten Windsor of his styles, titles and honours, he remains legally a duke
Writing in NLJ this week, Sophie Ashcroft and Miranda Joseph of Stevens & Bolton dissect the Privy Council’s landmark ruling in Jardine Strategic Ltd v Oasis Investments II Master Fund Ltd (No 2), which abolishes the long-standing 'shareholder rule'
In NLJ this week, Sailesh Mehta and Theo Burges of Red Lion Chambers examine the government’s first-ever 'Afghan leak' super-injunction—used to block reporting of data exposing Afghans who aided UK forces and over 100 British officials. Unlike celebrity privacy cases, this injunction centred on national security. Its use, the authors argue, signals the rise of a vast new body of national security law spanning civil, criminal, and media domains
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