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

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