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Costs of reorganising trading group

Allowable or not?

One of  those questions that seems to cause no end of disagreement (and I'm not expecting a unanimous decision here!)

Group was reorganised, involving creation of new companies and transfer of parts of the trades to those new companies. I'm satisfied that the legal and other professional costs should be largely, if not wholly, disallowed. But the suggestion from the client is that since part of the work was to do with the transfer of the trade (rather than the reorganisation, which he accepts is capital) the 'trade' element of the costs should be allowed. But I'm not sure that you can correctly say that costs of transferring a trade have been incurred W & E for the purposes of the trade. Or can you?


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10th Nov 2017 16:13

When you transfer a trade surely what you in effect are doing is selling goodwill which is of course an asset, so surely costs relate to disposal and acquisition of an asset.

The fact that no price may have been recognised is surely pretty immaterial.

Accordingly hard to justify the costs are W & E for the trade itself, they are surely W & E re who now owns the trade.

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10th Nov 2017 16:13

Why Anonymous?

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