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HMRC internal manual

Shares and Assets Valuation Manual

HM Revenue & Customs
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ITEPA: Market Value

All chapters within Part 7 of ITEPA (section 62 is in Part 3 Chapter 1) now use the Capital Gains Tax definition of market value as does the related legislation on Corporation Tax deductions in Schedule 23 Finance Act 2003.

Section 421 ITEPA provides that ‘market value’ has the same meaning as it does in Part 8 of the Taxation of Capital Gains Act (TCGA), in particular, sections 272 and 273.

As indicated in this chapter at SVM109030, joint elections are usually made when securities are acquired, for an unrestricted market value (UMV) to apply. The UMV is simply the market value of the securities ignoring the restrictions (usually all of them) in question.

  Additional Guidance: SVM150000