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HMRC internal manual

Business Income Manual

Builders, property dealers & developers: valuation: contentious appeal

Before making arrangements for a contentious appeal hearing before the First-tier Tribunal on a trading income valuation point, a report, accompanied by the file, should be made to CTISA (Technical).

The report should set out:

  • the amount of tax at stake as a result of the disputed valuation, and
  • confirm that the principle of using open market value has been accepted by the taxpayer and that it is only the amount of the valuation which is in dispute.