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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Valuation: interested parties: shares

Persons who own shares in the same company are not interested parties for the purpose of the regulations even if their holdings are identical in size. Regulation 15 limits interested parties to those persons whose own Capital Gains Tax liability would be affected by a valuation or apportionment. A persons own liability could not be affected by a valuation of another persons shares even if the size of the holdings is identical.