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HMRC internal manual

Shares and Assets Valuation Manual

Tax Advantaged Share Schemes: suggestion of price

It is for the company - through its agents - to suggest the price proposed. Sometimes companies prefer that the price reflects a pro rata part of the company value without any discount for minority status. If you are satisfied that the price exceeds the market value then you can simply accept the suggested price on a without prejudice basis.

However, you should make it clear that you consider that the price proposed exceeds market value. You should add that a price that exceeds market value cannot be replied upon for other fiscal valuations, including those required for determining deductions for Corporation Tax purposes. See Chapter 109 of this manual at SVM109070.

  Additional Guidance:SVM150000