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HMRC internal manual

Shares and Assets Valuation Manual

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HM Revenue & Customs
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Introduction: Quoted Shares

Whilst Shares and Assets Valuation (SAV) mainly deals with the valuation of shares that do not have a listing on a recognised stock exchange, there are occasions when we have to consider the value of quoted shares.

File Assessment Creation and Examination Team (FACET), part of the Inheritance Tax group, checks values of quoted shares for tax purposes.

FACET refers the following matters to SAV:

  • CGT cases where it is considered that there are ‘special circumstances’ in consequence of which the prices quoted are not a proper measure of the market value (Section 272(3) TCGA 1992.
  • Claims that by reason of its size a holding should have a special reduction in price. (Such reductions are precluded by the IHT and CGT legislation.)
  • All cases where any individual holding of shares with a full listing is valued at over £10,000,000 and / or a holding of shares listed on a junior market exceeds £100,000 in value.
  • Suspended quotations. (FACET will provide prices for the last day before the quotation was suspended and the first date after the quotation was re-opened, if appropriate.)
  • Cancelled quotations, unless and until it is clear that the company is now an NQ and the former quotation is irrelevant for valuation purposes.
  • Claims that shares, following suspension or cancellation of a quotation, have become of negligible value for CGT.

SAV’s procedures for dealing with valuation issues relating to quoted securities for CGT purposes are explained in Chapter 107 of this Manual - CGT Procedures. SVM107000.

Valuations of shares that are quoted on a foreign stock exchange can be referred to SAV. See SVM101030 below.

  Additional Guidance: SVM150000