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HMRC internal manual

Business Income Manual

Builders, property dealers & developers: valuation: not negotiated valuation: no current tax effect

Where the District Valuer’s not negotiated valuation gives rise to an adjustment that has no current tax effect, you should write to the taxpayer and explain that:

  • neither valuation gives rise to a current tax effect;
  • you do not intend to take any further action at present;
  • this should not be taken as agreement to the taxpayer’s valuation and negotiations will be resumed if there is any future tax liability which will be affected by that valuation;
  • if the taxpayer wishes, however, you will ask the District Valuer to enter into negotiations to try to reach an agreed valuation.

You should only take this action where the District Valuer’s not negotiated valuation gives rise to a substantial adjustment (see BIM51570). Otherwise, the accounts figure should be accepted.

Valuation arguments should not normally be entered into where there can be no possible current or future tax effect.