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.
| Aspect | Detail |
|---|---|
| Valuation method | Earnings multiple, NAV, DCF, and market value at relevant date |
| BPR qualification | Trading vs investment business test analysis |
| SAV challenge | Independent counter-valuation to HMRC SAV position |
| BADR conditions | Personal company and qualifying period assessment |
Frequently Asked Questions
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