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HMRC internal manual

Shares and Assets Valuation Manual

The Statutory Open Market: Case Law - Hindsight

In S Patrick Erdal v HMRC [2011] UKFTT 87 TC the Tribunal Judge J Gordon Reid Q.C., F.C.I.Arb said:

“It is also an accepted principle of valuation that the valuer stands at the valuation date looking forward into the future with reasonable foresight, rather than looking back today with hindsight at the valuation date. However, regard may be had to later events for the purpose only of deciding what forecasts could reasonably have been made on 31 March 1982. The question of reasonable foresight is of particular importance in this appeal when coupled with the statutory direction to assume that the prospective purchaser has all the information which a prudent prospective purchaser might reasonably require if he were proposing to buy from a willing seller by private bargain at arm’s length.”

  Additional Guidance:SVM150000