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The Special Commissioners made the right decision in the recent shares valuation case, Company A, says DAVID BOWES.
KEY POINTS
- The relevance of the subscription agreement.
- To what extent does the hypothetical seller step into the shoes of the real transferor?
- The sale may be hypothetical but the open market is real.
- For the taxpayer to win on a future appeal more than a century of case law would have to be overturned.
A significant part of my professional life is spent negotiating with HMRC in relation to share valuation matters and I have on many occasions ultimately been able to persuade them to agree a favourable valuation...
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