INTM578080 - Thin capitalisation: interest cover
The effect of amortisation
Amortisation of goodwill involves debiting to the profit &
loss account over a period of years the amount paid for a business
acquisition above the value of the tangible assets acquired. As
such, it does not usually reflect a cash expense in the year in
which it is debited, and it is sometimes contended that it should
be added back in the calculation of interest cover. The HM Revenue
& Customs response to this contention depends upon the business
that has been acquired. If the reasonable projections for that
business show that it is likely to be profitable in the immediate
and foreseeable future, then the write-down of the original cost of
goodwill should be counteracted by the additional future profits.
In such circumstances HM Revenue & Customs will generally agree
that amortisation can be added back, but it is dependent upon the
facts of a particular case. In cases where EBITDA is used, it is
normal to look for a higher ratio than when EBIT is used.
Before an Inspector will agree to the add-back of
amortisation it will be necessary to demonstrate that the future
profits of the acquired business will outweigh the costs –
that there is a genuine reason to believe that the synergies of the
acquisition are positive.
