Goodwill and trade related properties

We have a situation where HMRC is arguing that the Goodwill Paid by our client on an arms length transaction relating to a Care Home Business should be NIL when applying Intangible legislation for Goodwill measured according to UK GAAP. Our client paid over 30% of the Total value as Goodwill. If the Goodwill value is reduced to NIL this will have an immediate impact on the Tax liability. This seems to be an unfair move by HMRC when Care Home Industry is along with other trading businesses of this nature are going through difficult time.

 

Has anyone else come across this situation? Any input would be appreciated.