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HMRC internal manual

Capital Gains Manual

Goodwill and Intellectual Property Rights: disputed valuations and appeal hearings

If Shares and Assets Valuation (SAV) are unable to reach agreement with the taxpayer or their agent on a valuation and have confirmed that the information necessary to inform an expert witness has been provided it may be necessary for the matter to be heard by the First-tier Tribunal.

In advance of the hearing SAV will send you a report giving their proposed valuation(s) at the date(s) in question. After receiving the report and subject to SAV’s agreement, you should issue any Closure Notices or, where appropriate, Capital Gains Tax or Corporation Tax assessments, based on the valuation(s) supplied. You should handle any appeal in the normal way and then refer the papers to the CG Technical Group.

Cases where Counsel is likely to be involved should be reported under the procedures at AH0645.