England & Wales · CPR 35 / FPR 25

BVExperts

Business Valuation Methods Used by UK Expert Witnesses

The Three Primary Methods

UK courts do not prescribe a single valuation method - the appropriate method depends on the type of business, the purpose of the valuation, and the legal context. Expert witnesses must justify their choice of method and demonstrate that it produces a reliable result.

1. Discounted Cash Flow (DCF)

Definition: DCF values a business by projecting future cash flows and discounting them back to present value using a risk-adjusted discount rate (typically the Weighted Average Cost of Capital - WACC).

When used: Growing, profitable companies with reliable forecast data - particularly technology firms, professional services, and SaaS businesses.

DCF methodology steps used by UK business valuation expert witnesses
StepDescriptionKey Variable
1. Revenue forecastProject 3–5 year revenueGrowth rate assumptions
2. Free cash flowCalculate EBITDA → FCFEBITDA margin, capex
3. Discount rateCalculate WACCCost of equity, cost of debt
4. Terminal valueGordon Growth Model or exit multipleLong-term growth rate
5. Enterprise valueSum PV of FCFs + terminal valueEV to equity bridge

Strengths: forward-looking; captures growth potential. Weaknesses: highly sensitive to assumptions; contested in litigation.

2. Maintainable Earnings (Capitalisation of Earnings)

Definition: Values a business by applying an earnings multiple to a normalised, maintainable level of earnings (typically EBIT or EBITDA). The multiple reflects sector, risk, and comparable transaction data.

When used: Established trading companies with stable earnings - traditional businesses and owner-managed SMEs.

Maintainable earnings (capitalisation of earnings) methodology
StepDescriptionKey Variable
1. Normalise earningsAdjust for owner salary, one-off items, related party transactionsMaintainable EBIT/EBITDA
2. Select multipleSector comparables, market data, transaction multiplesEV/EBITDA multiple
3. Apply multipleMaintainable earnings × multipleEnterprise value
4. Equity bridgeDeduct net debt, add surplus assetsEquity value

Strengths: simple, market-referenced. Weaknesses: multiple selection is subjective; contested between experts.

Definition: Values a business based on the value of its underlying assets minus liabilities - at book value, fair value, or forced sale value.

When used: Property-holding companies, investment companies, loss-making businesses, and businesses being wound up.

Net asset value (NAV) methodology for UK litigation
StepDescriptionKey Variable
1. Asset scheduleList all assets (tangible + intangible)Balance sheet
2. Revalue assetsMark to market (properties, investments)Independent valuations
3. Identify liabilitiesAll debts, contingent liabilitiesLegal due diligence
4. NAVAssets minus liabilitiesGoing concern or break-up

Fair Value vs Fair Market Value - UK Legal Context

UK business valuation expert witnesses must apply the valuation standard directed by the court or statute - fair market value in many commercial and tax matters, fair value in S994 unfair prejudice petitions.

Fair market value vs fair value (S994) for UK shareholder disputes
TopicFair market valueFair value (S994)
DefinitionPrice between willing buyer and seller without compulsionLegal standard for unfair prejudice buy-out orders
Minority discountOften applied to minority stakesTypically disapplied where prejudice is found
Typical useTax, M&A, commercial transactionsCompanies Act 2006 s994 petitions
Expert reportCPR Part 35 / open market basisCPR Part 35; proportionate share of whole company

See our S994 shareholder dispute valuation guide and solicitor guide to fair value.

Discounts & Premiums

  • Minority Discount: reduction for lack of control; contested in S994 - courts often disapply where unfair prejudice is found.
  • Control Premium: uplift for majority or controlling stakes.
  • Marketability Discount (DLOM): reduction for illiquid private shares; more common in US courts, applied selectively in the UK.

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