The appellant company was entitled to deductions under the intangible fixed assets regime on expenditure which it considered to have been incurred on intangible fixed assets, comprising a licence to use a client list, data and information relating to clients of an accountancy practice.
The appellant company’s (RL’s) owners and directors were two individuals (PG and RG). In April 2007, PG and RG incorporated a limited liability partnership (RLLP) to operate an accountancy business. RL was set up to own an asset which RG considered he acquired when he and PG ceased to be partners in a chartered accountants partnership (GCA). They retired from GCA on or around 31 May 2007. RG decided to set up a new accountancy practice with PG 
