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FTT (Tax) upholds HMRC: no GAAP-recognised goodwill as control remained with partnership; amortisation debits disallowed (Milton Park Holdings Ltd v HMRC)

Published on: 25 November 2025

Published by a LexisNexis Tax expert
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Milton Park Holdings Ltd and another v HMRC [2025] UKFTT 1353 (TC)

A partnership (MPP) ran a care homes business from properties that were owned by two of the individual partners. Two corporate partners, BHL and BCSL, which were controlled by those individual partners, supplied staffing and administrative services. The background to the dispute comprised the following transactions:

  • The individual partners incorporated a company, MPHL, in Jersey.
  • MPHL acquired the business and assets of MPP, including an asserted £173 million of goodwill, which it subsequently amortised in its accounts.
  • MPHL also acquired another company, MPL, from one of the individual partners.
  • MPL entered into a partnership (MCP) with (i) the son of one of the individual partners, (ii) BHL, and (iii) BCSL to carry on the nursing home business...

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