HMRC Share Valuation Disputes: Expert Witness Guide

HMRC's Shares and Assets Valuation team provides valuations for tax purposes including Inheritance Tax, Capital Gains Tax, and employment-related securities. Taxpayers may accept SAV's valuation, negotiate, or challenge via tribunal with independent expert evidence.

Expert witnesses prepare open market value analyses using DCF, earnings multiples, or NAV consistent with the tax charge in question.

Inheritance Tax disputes often involve business property relief - whether a company qualifies and the open market value of shares if relief is restricted. CGT on private company disposals requires valuation at disposal date. ITEPA 2003 covers restricted shares, EMI options, and growth shares.

Section 431 elections and corporate reorganisations may trigger valuation disagreements requiring specialist input.

Unresolved disputes proceed to the First-tier Tribunal. Expert witnesses give written reports and may attend hearing. Tribunals assess methodology and assumptions - clear explanation for non-specialist members is essential.

Early expert involvement can support without prejudice negotiation with SAV before litigation. Ensure the expert understands the statutory valuation standard applicable to each tax - open market value definitions may differ from fair value in company law contexts.