CGT Share Disposal Valuation Expert Witness UK

Capital Gains Tax share disposal valuation disputes arise where HMRC's Shares & Assets Valuation (SAV) team provides valuations for CGT purposes on disposal of unquoted shares, and the taxpayer disagrees with the adopted value. The tax expert witness produces independent counter-valuations applying appropriate methodology, earnings multiple, NAV, or DCF, and defends the analysis before the FTT if necessary.

Business Asset Disposal Relief (BADR, formerly Entrepreneurs' Relief) disputes arise where HMRC challenges whether the qualifying conditions are met, particularly the personal company test (5% shareholding and voting rights), the officer or employee requirement, and the 24-month qualifying period. Expert witnesses provide technical analysis of the qualifying conditions and their application to the facts.

CGT valuation disputes frequently involve questions about market value at the disposal date, the impact of minority discounts and lack of marketability, and the correct treatment of deferred consideration and earn-out arrangements.