.png)
.png)
Basis of valuation
The appellant acquired the shares in a company in November 1981 in an arm's length transaction for £152 634. The company's main asset was a leasehold property in London. In December 1988 the appellant sold its shareholding for £397 365 to the buyer who was a tenant of the property. The Revenue issued a capital gains tax assessment on the value of the disposal of the shareholding as at 31 March 1982 as by virtue of FA 1988 s 96 the appellant was deemed to have disposed of and reacquired its holding on that date at its then market value.
On appeal the Special Commissioners referred the property valuation to the Lands Tribunal asking whether or not there was a special purchaser as at 31 March 1982 and if so how that would affect the value. The Lands...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
