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HMRC internal manual

Business Income Manual

Stock: valuation on discontinuance of business: resolving disputes

S171 Corporation Tax Act 2009 and S186 Income Tax (Trading and Other Income) Act 2005

Where stock has been transferred from a ceasing business to another UK business, and there is a dispute regarding the correct value of the closing stock for the ceasing business and the acquisition cost for the succeeding business then both parties will have to be informed if the dispute is to be resolved by taking the case to the Tribunal to be determined in the same way as an appeal. Any decision will be binding on both parties.

Where the stock is not transferred to another UK business then any enquiry about the value should be resolved using the usual ITSA or CTSA procedure.