A wide range of UK tax events depend on the open-market value of unquoted shares: EMI option grants, Section 431 elections, transfers between connected parties, restructurings, share-for-share exchanges and post-transaction rulings. Where HMRC is or may become involved, an independent valuation is the foundation of the position taken in the tax return or election.
When is it required?
- EMI VAL231 advance agreement submissions.
- Post-transaction valuation rulings (PTVR).
- Share-for-share exchanges and group reorganisations.
- Employment-related securities (ERS) reporting.
Our methodology
We apply the hypothetical purchaser-and-vendor test (section 272 TCGA 1992; section 160 IHTA 1984), using earnings multiples, net asset value and DCF as appropriate, with discounts and waterfall analysis tailored to the share class and tax purpose.