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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Assets: principles of valuation: where collective valuation may apply

The principle that emerges from Gray may be applicable to Capital Gains Tax valuations in cases where more than one asset is actually included in a single disposal and in cases where the statutory hypothesis on which the valuation is based deems two or more assets to be disposed of together. Examples of the latter include

  • an acquisition by personal representatives or legatees under TCGA92/S62 of assets of which a deceased person was competent to dispose, see CG30330
  • an acquisition of settled property under TCGA92/S71(1) on the occasion of a person becoming absolutely entitled to that settled property, see CG37000+.

Where the principle established in Gray is followed, so as to value a number of assets collectively to produce a total valuation in excess of the value of the assets valued separately, an apportionment will be required in accordance with TCGA92/S52(4). The apportionment is to be made on a just and reasonable basis and so must reflect the value of each of the assets, see CG14771+. Commonly this will require an apportionment of the total value in proportion to the value of each asset.