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Section 16: shares and assets valuation

Valuation Office Agency

October 17
12:25 2023

Part 1

Introduction

16.1 Shares and Assets Valuation

Shares and Assets Valuation (SAV) is a section of HMRC mainly dealing with the valuation of unquoted shares. SAV also provides specialist valuation advice to HMRC in respect of a variety of other assets including goodwill, livestock, bloodstock, patents and royalties, gold and other bullion, ships and aircraft, mobile homes and wine.

VOA assistance to SAV

16.2 General

SAV will usually request advice from the VOA in one of two circumstances, namely:

  • when the value of shares in an unquoted company reflects wholly or substantially the value of underlying assets comprising either freehold (feuhold in Scotland) or leasehold property, or plant or machinery, owned by that company, SAV will refer the case to the VOA for a valuation of those assets (see para 16.3); or
  • when SAV is asked to provide a valuation of goodwill in a business and deccides that a property valuation will also be required (see para 16.16 below.)

16.3 Assistance in ascertaining the value of a shareholding

When SAV has requested valuation advice in order to determine the value of the shareholding transferred, caseworkers should not enter into discussion with the taxpayer or their representative concerning the value of the shares.

In such cases, it should be noted that there is no requirement for the VOA to ascertain the value transferred or the value of the property transferred since these terms relate to the value of the shareholding, which is a matter for SAV. The property which is required to be valued has not of itself been transferred (see also para 16.8).

References from SAV

16.4 General

Most references from SAV will be forwarded on form SAV/VOA1 (Appendix 5). However, the following types of SAV cases will normally be referred by memorandum (see also para 16.44 below):

  • goodwill,
  • minerals,
  • shipping and air transport,
  • SDLT,
  • foreign property,
  • plant and machinery
  • milk quotas
  • cases forwarded via the Land Portfolio Valuation Unit (LPVU).

16.5 Information on Form SAV/VOA1

As well as giving the name of the taxpayer, the company involved and details of the officer dealing with the case, Form SAV/VOA1 will contain the following information:

  1. the nature of the tax e.g CGT/SDLT/IHT);

  2. the date of valuation;

  3. the total value returned for the property(ies);

  4. details of the tolerance range within which the returned value can be accepted (normally this will be the larger of 15% or 30,000, if different tolerances are to be utilised the box will be ticked and details of the tolerances required will be included on a separate memorandum);

  5. details of any other SVT sector geographical areas involved

SAV will normally provide details of the properties to be valued on Form CAP37 (Appendix 7).

16.6 Information on Form CAP37

Form CAP37 again contains details of the company involved, the date of valuation and SAV reference. This form is normally completed by the taxpayer or their agent and additionally will contain:1. The name and address of any person the VOA should contact, together with their reference and telephone number (but see para 16.32 below);2. for each item number (column 1), the full address or description of the property to be valued (colu

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