Share valuation fluctuations

This was a lead case where the common issue concerned the value of BBG shares at various dates.

The first taxpayer M acquired shares in BBG in anticipation that it would buy a business with the BBG shares then floated on a stock exchange. The second taxpayer T began a business BBL which he then wished to sell in 2006. He sold the BBL shares to BBG for some £12m cash deferred consideration of £250 000 and shares in BBG.

In November 2006 BBG was floated on the Channel Islands Stock Exchange at a share price of 108p.

Since that time both taxpayers gifted shares to charity and claimed income tax relief based on what they believed to be the market value of the shares at the time of the gifts.

After an enquiry HMRC issued closure notices claiming that the market...