IHT & CGT Valuation Disputes

IHT and CGT disputes frequently turn on the value of unquoted shares, business interests, or property at a specific date. Tax expert witnesses address both the correct valuation methodology and whether HMRC SAV's adopted value is defensible.

Business Property Relief disputes require analysis of the trading vs investment test under IHTA 1984 s105. CGT share disposal disputes involve earnings multiple, NAV, or DCF methodology and minority discount analysis.

Expert counter-valuations are essential where the tax liability depends on a valuation difference of hundreds of thousands or millions of pounds.

AspectDetail
Valuation methodEarnings multiple, NAV, DCF, and market value at relevant date
BPR qualificationTrading vs investment business test analysis
SAV challengeIndependent counter-valuation to HMRC SAV position
BADR conditionsPersonal company and qualifying period assessment
Related guide →

Frequently Asked Questions

HMRC's Shares & Assets Valuation team provides valuations for IHT and CGT purposes on unquoted shares and business interests. Where the taxpayer disagrees, a tax expert witness produces an independent counter-valuation and defends the methodology before the FTT.

Instruct a tax expert witness

Tell us about your UK tax dispute and we will match you with a qualified expert witness experienced in HMRC enquiries and tribunal proceedings. We aim to respond within one working day.

Make an enquiry