HMRC Valuation Dispute & Tax Tribunal Expert Witness
HMRC's Shares and Assets Valuation (SAV) team provides valuations for tax purposes that taxpayers and their advisers may challenge. Independent expert witnesses prepare counter-valuations for negotiation with HMRC or for hearing before the First-tier Tribunal (Tax Chamber).
Common disputes include Inheritance Tax business property relief, Capital Gains Tax on private company disposals, employment-related securities under ITEPA 2003, and section 431 elections. Methodology must reflect open market value or the statutory standard applicable to each charge.
Experts combine tax law awareness with rigorous financial analysis - DCF, earnings multiples, or NAV - and explain assumptions clearly for non-specialist tribunals.
Common questions
- Can an expert witness challenge HMRC's business valuation?
- Yes. HMRC's Shares and Assets Valuation (SAV) team provide valuations for tax purposes, but these can be challenged. An independent expert witness prepares a counter-valuation applying appropriate methodology and presents it to HMRC for negotiation or, if unresolved, to the First-tier Tribunal (Tax Chamber) for determination.
- What tax issues most commonly require business valuation experts?
- Inheritance Tax (business property relief disputes and open market value of shares); Capital Gains Tax on disposal of private company shares; Employment Related Securities (restricted shares, options, growth shares); and corporate transactions where HMRC challenges the value placed on shares or goodwill.
Next step
Ready to instruct a business valuation expert witness?
Submit your case details and we will match you with a qualified expert for English and Welsh proceedings under CPR Part 35 or FPR Part 25. Response within one business day.
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