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HMRC internal manual

Capital Gains Manual

Absolute entitlement: valuation

Where, therefore, the total number of shares deemed to have been disposed of by thetrustees represents a majority holding, the shares must be valued on that basis eventhough each of the beneficiaries may have become absolutely entitled to sharesrepresenting only a minority holding. The valuation of unquoted shares is a matter forShares and Assets Valuation, but it is the Inspector’s responsibility to tell SAV what isto be valued. (As a general rule the value per share increases as the percentage holdingincreases.)