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HMRC internal manual

Partnership Manual

Indirect, capital and transfer taxes and other tax obligations: Capital gains: Goodwill

CG68100 contains guidance on the goodwill of a partnership business. It is important to remember that goodwill is not capable of being separated from the business with which it is associated. This is an important principle supported by case law (see CG68030) and accountancy principles (FRS7 and FRS10). Individual partners may acquire or dispose of their fractional interests in the goodwill of the partnership business but the goodwill itself can only be transferred with a transfer of the whole business.