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1894 and all that
KEY POINTS
- A valuation for tax purposes should assume an imaginary sale a hypothetical prudent purchaser and a vendor who has to sell on the relevant date.
- The prudent prospective purchaser can seek all the information he might reasonably require but only if it is available.
- Three categories of information were identified in case law: published management and confidential.
- Management accounts rather than historic accounts may be more relevant for valuation purposes.
- Hindsight cannot be used in a valuation except when events could reasonably have been foreseen.
The changing fortunes of companies and business assets will affect their value and that of the equity owned by their shareholders. This will in turn affect the potential tax liabilities that may arise as a result of transactions...
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