9
May
2006
Special Commissioners decision changes view on Franchises Goodwill
In 1996, 32 Pizza Express franchisees sold their businesses back to the franchisor Pizza Express. Two of these businesses claimed capital gains tax rollover relief in respect of the gain on goodwill under TCGA 1992, s. 152. The claim was subsequently refused by HMRC and the tax payers appealed. HMRC’s argument was that there was …