Chancery Division.

Park J.

Judgment delivered 2 October 1998.

Capital gains tax – Valuation of shares in private company – Base value to be market value on 31 March 1982 – Revenue valued shares in cash and carry business as a going concern – No figure for goodwill included – No evidence of goodwill value adduced before special commissioner – Whether court could assess base value itself or remit case to special commissioner to consider whether a figure for goodwill should be added to Revenue’s valuation – Capital Gains Tax Act 1979, s. 150, 152 (Taxation of Chargeable Gains Act 1992, s. 272, 273).

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