Countrywide Estate Agents FS Limited v HMRC

Stephen Brandon QC and Harriet Brown represented the Appellant in its appeal against amendment of its return such that £25 million was brought into charge. The case concerns whether a lump sum given in consideration for the granting of a very long-term exclusive right over the goodwill of a trader constituted a capital or income receipt.

The First Tier Tribunal held that it was an income receipt. Leave to appeal to the Upper Tier Tribunal has been sought, and a decision is expected shortly.
A copy of the judgment can be downloaded below.

12 October 2010

Countrywide