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Engaged in a battle with HMRC over share valuations? MIKE THEXTON suggests a suitable strategy
KEY POINTS
- The advantage of HMRC's numerical experience in valuation.
- Using the 'post-transaction valuation check'.
- The legal hypothesis of valuations.
- Obtaining supporting evidence — what can be considered?
- HMRC now also consider the cost effectiveness of valuation disputes.
Oscar Wilde wrote that a cynic knows the price of everything and the value of nothing. The Parliamentary draftsman disregarded Oscar's clever distinction in TCGA 1992 s 272: 'market value in relation to any assets means the price which those assets might reasonably be expected to fetch on a sale in the open market'. That's easy to establish in the case of quoted shares but almost any other asset poses problems.
One practical issue is that if it comes down to arguing about values with the Shares and Assets Valuation Division (SAV) of HMRC...
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