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HMRC internal manual

Capital Gains Manual

Valuation: more than one interested person: purpose of regulations

For example, in a transaction between connected persons each has an interest in the figure which is determined as the market value of the asset transferred at the date of the transaction. That market value determines the disposal proceeds to be credited in the computation of the vendor and the cost to be debited in any subsequent disposal by the purchaser. Without the regulations the market value could have to be determined twice, in determining two separate appeals. This would be time consuming and could lead to inconsistent results. With the regulations the market value or apportionment is binding on each party who has been given an opportunity to be joined. This is so whether or not they have taken that opportunity.