Goodwill can form part of the price of an established business, but capital borrowed against the assets of the enterprise itself is not the investor's own funds at risk. A loan secured on the investor's personal assets, for which the investor is personally liable, ordinarily can count.
Who bears the loss decides whether the money counts
Hypothetical example: Xavier is buying an American business whose price is mostly goodwill and a customer list, financing half of it with a loan secured against the assets of the business he is acquiring. The security is the difficulty. Where the enterprise's own assets stand behind the debt, it is the business rather than Xavier that bears the loss, and that portion is not treated as his capital at risk.
Had he mortgaged property he owns personally and taken on personal liability, the position would ordinarily be different. Goodwill and intangible assets can legitimately form part of what an established business costs, but a price weighted heavily toward them invites scrutiny of the valuation, so a supported valuation is worth having. Separately, the government charges are a minor part of the budget and should be taken from the current fee schedule rather than a quoted figure, while the substantial costs are valuation, legal work on the purchase and the business plan the file will rest on.