Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Shares and Assets Valuation Manual

From
HM Revenue & Customs
Updated
, see all updates

Case Selection, Handling and Settlement: Risk Assessment

SAV operates a two tier Risk Assessment process:

1st Tier Risk Assessment

This is the first opportunity for Risk assessors to:

  • Accept a value returned without question
  • Suggest an alternative informal valuation to the case-owner
  • Explain to the case-owner why SAV is unable to consider the value returned, for example, due to a lack of information
  • Recommend to the case-owner whether an enquiry should be opened to enable SAV to acquire missing information and pursue the valuation
  • Refer cases not considered appropriate for 1st Tier Risk Assessment for 2nd Tier Risk Assessment

2nd Tier Risk Assessment

Cases that are not appropriate for 1st Tier Risk Assessment, for example due to complexity, are allocated to valuers for further investigation. Having given the case full consideration the valuer may at this stage:

  • Accept a value returned without question
  • Suggest an alternative informal valuation to the case-owner
  • Explain to the case-owner why SAV is unable to consider the value returned, for example, due to a lack of information
  • Recommend to the case-owner whether an enquiry should be opened to enable SAV to acquire missing information and pursue the valuation
  • If an enquiry is already open, agree with the case-owner that SAV will contact the taxpayer/agent and commence investigation of the valuation

The primary considerations for you as a share valuer are likely to be the strength of the facts and arguments that may be adduced in support of a valuation adjustment and the materiality of such an adjustment in terms of tax. However, when you are considering a risk assessment, it is important to remember that the valuation may be only part of a bigger picture. The case owner may have other factors to consider for example, the overall behaviour of a particular taxpayer or a desire to concentrate effort into a particular sector. A valuation may have materiality beyond the tax at risk in the immediate case, because of wider deterrent or clarification effects.

 

  Additional Guidance:SVM150000