Prudent taxpayer must use all publicly available data

In 2004 the taxpayer made gifts of shares in a company called Access Intelligence plc to the Lord’s Taverners - a charity. He claimed relief under TA 1988 s 587B on the basis that the shares were worth £80 750. In 2018 after an enquiry HMRC issued a closure notice reducing the relief on the shares based on a valuation of £17 936.

The taxpayer appealed.

The issue for the First-tier Tribunal was to determine is the market value of the shares at the time of the relevant gift. HMRC valued them at 9.44p each as against the taxpayer’s valuation of 42.5p per share.

The taxpayer said he received the shares as a gift from a friend after that friend sold their interest in another company. He said the AIM information was the only information available to him as a small shareholder.

HMRC’s expert valuer had formed the view...