The following Tax Q&A provides comprehensive and up to date legal information covering:
If shares are later sold for more than a post-transaction valuation agreed with HMRC, then whether HMRC can revisit that valuation will depend on the facts. There may be good reasons why the value of shares has increased since their valuation was agreed with HMRC, eg there may have been a takeover bid for the issuing company in the meantime. HMRC may still be tempted to revisit the valuation, especially if the sale occurred not long after the valuation was agreed. In general, the use of hindsight (ie taking account of information that was not available at the time or events that occur after the relevant time) is prohibited when agreeing tax valuations. However, case law has established that evidence of actual transactions may be relevant to a valuation, even if they occur subsequently and even if they may not be reasonably foreseeable at the valuation date—such transactions should be used as a check or sounding board for a conclusion reached by a primary valuation approach. The precise relevance of subsequent transactions
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