Fiscal share valuations

Produced by a Tolley Owner-Managed Businesses expert
Owner-Managed Businesses
Guidance

Fiscal share valuations

Produced by a Tolley Owner-Managed Businesses expert
Owner-Managed Businesses
Guidance
imgtext

Valuations may be required for tax purposes in many different scenarios, including:

  1. on grant of share options to employees in a tax-advantaged share scheme

  2. to ‘rebase’ assets to their value as at 31 March 1982

  3. where assets are transferred between connected parties

  4. where shares are acquired at undervalue by reason of someone’s employment

This guidance note is concerned with share valuations for tax purposes. For guidance on performing share valuations more widely, including for commercial purposes, and the risks involved for the practitioner, see the Professional valuations guidance note. For guidance on specific commercial valuation methods which may also be relevant to tax valuations, see the Measures and methods of valuation guidance note.

Definitions

There are two relevant definitions in the Taxes Acts for the purpose of private company share valuations.

‘Market value’ is defined in TCGA 1992, s 272 and in IHTA 1984, s 160. It is essentially the amount which could be fetched on the open market between an arm’s length vendor and purchaser. The statutory definitions are limited, and therefore the

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+
  • 11 Dec 2025 15:50

Popular Articles

Residential property and capital allowances

Residential property and capital allowancesResidential property ― plant and machinery allowancesOrdinary residential property does not, and never has, qualified for capital allowances. as CAA 2001, s 35 denies plant allowances for expenditure incurred in providing plant or machinery for use in a

14 Jul 2020 17:14 | Produced by Tolley in association with Martin Wilson and Steven Bone Read more Read more

Self assessment ― amendments and corrections

Self assessment ― amendments and correctionsOnce a self assessment tax return has been filed, both HMRC and the taxpayer (or the agent) has the right to make changes to the return. There are different time limits depending on whether it is a correction by HMRC or an amendment made by the

14 Jul 2020 13:37 | Produced by Tolley Read more Read more

Computation of corporation tax

Computation of corporation taxCompanies pay corporation tax on the taxable total profits (TTP) generated in a chargeable accounting period (CAP).To ascertain whether the entity is within the charge to corporation tax, see the Charge to corporation tax guidance note.For more information on the type

14 Jul 2020 11:16 | Produced by Tolley Read more Read more