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HMRC internal manual

Capital Gains Manual

Land: valuation: unagreed: no possible tax effect

In some cases the valuation of land in dispute may have little or no effect. This may be the case where, for example, both the taxpayer’s valuation and the Valuation Office Agency’s unagreed valuation give rise to gains which are below the annual exempt amount for that year and no other gains accrue to the taxpayer in the same year; or because both valuations give rise to losses for a company which has subsequently been wound up and the losses will never be used.

In these cases you should

  • write to the taxpayer and explain that because there is no tax at stake on either valuation you will accept the returned gain or loss without prejudice to the valuation put forward by the Valuation Office Agency
  • inform the Valuation Office Agency that the unagreed valuation has no possible tax effect, and that you are therefore accepting the taxpayer’s computation without prejudice to the Valuation Office Agency’s valuation, so that his or her file can be closed.

If the valuation dispute does not currently have any effect on an appeal, as explained above at CG74503, it will not be possible for that valuation dispute to be referred to the Lands Tribunal. This will also apply to any post transaction valuation check where it is not possible to reach agreement.