Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Share valuation fluctuations

19 July 2021
Issue: 4801 / Categories: Tax cases
N McArthur and T Bloxham (TC8186)

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...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon