This section considers SP D12, para. 1: Valuation of a partnerʼs share in a partnership asset.

‘Market value’ is the price which the assets might reasonably be expected to fetch on a sale in the open market.

For the purposes of determining the market value of a partner’s share in a partnership asset for CGT purposes, it will be taken as a fraction of the value of the total partnership interest in the asset without any discount for the size of the partner’s share.

Example 1 (reproduced from HMRC’s Capital Gains Manual at CG27250)

A partnership between Y and Z owns 70% of the issued share capital of X Ltd.

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