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Green (TC3525)
A taxpayer made gifts to two charities of 118 750 shares each. He claimed relief of £237 500 under ITA 2007 s 431 based on a market value of £1 a share.
HMRC restricted the amount to £71 250 valuing the shares at 30p each. The taxpayer appealed.
Both parties at the First-tier Tribunal presented expert share-valuation reports. The Revenue’s offered a discounted cash flow valuation of the company using revenue and earnings projections that would not have been available on the open market. It concluded that the shares were worth between 25p and 30p.
The taxpayer’s report used the price/earnings (P/E) technique to value the shares in that it applied a multiple to the sustainable earnings of the company to produce an adjustable enterprise value. It concluded that the shares’ value was between 88p and 93p.
The tribunal decided the taxpayer’s valuation method was...
