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HMRC internal manual

Capital Gains Manual

Valuation: more than one interested person:Tribunal: application

For this purpose a market value or an apportionment is a material question in an appeal even if there is no dispute about that value or apportionment between the appellant and the Inspector. For example, in a transaction between connected persons the vendor and the Inspector may agree on the value of the asset at the date of sale. If the purchaser does not agree that valuation he or she is entitled to make an application to the Tribunal under regulation 9(1).