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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Introduction and computation: occasions of charge: assets lost/destroyed/negligible value: unquoted shares

TCGA92/S24(2) – unquoted shares

You may, at your discretion, accept a negligible value claim in respect of unquoted shares if you consider that the claim is free from doubt or difficulty, all other conditions for making a valid claim are met, and all of the following conditions are satisfied:

  • the company is registered in the UK, and
  • the company is not registered as a PLC, and
  • the capital loss arising from the deemed disposal of shares following the negligible value claim is under £100,000, and
  • the company
    • was in liquidation and insolvent, or
    • had ceased trading and had no assets

at the date of the claim and at any earlier date specified in the claim.

All other cases involving unquoted shares must be referred to Shares and Assets Valuation, see CG59540+.

It will still be necessary to ask Shares and Assets Valuation to agree any 31 March 1982 value of the shares, if appropriate.

In addition, a  claimant can ask for a post transaction valuation check after the negligible value claim has been made and before the return showing the loss arising from the deemed disposal is filed, see CG16600+.  You may accept that the post transaction valuation check is made after the claim is made if a form CG34 is submitted at the same time as the claim.  See CG13135 for guidance on the procedure for making a claim.  See CG13140 for an example where a form CG34 is submitted with a claim.

The guidance in this paragraph only applies to the acceptance that shares are of negligible value at the time the claimant makes a claim and at any earlier date specified in the claim.  It does not apply to other aspects, such as:

  • whether the shares became of negligible value so that the negligible value claim succeeds (see CG13125), or
  • the amount of any allowable loss that results from the negligible value claim (and any notice given under TCGA 1992/S16(2A)) and when you need to refer valuations to Shares and Assets Valuation in calculating the amount of a loss once it is established when and how shares were acquired, or
  • whether, if the negligible value claim is made in conjunction with a share loss relief claim, ITA07/S131 (see VCM70000+), the relief claimed under that section is allowable.