ERSM220020 - Valuation Issues

Basis of valuation

Old legislation

In the old legislation (which was rewritten in ITEPA as from 6 April 2003) the value of securities was variously:
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  • money바카라 사이트™s worth, which is something capable of being converted into money or something of direct monetary value (e.g. ITEPA03/S62 in Chapter 1 of Part 3),
  • what might reasonably be expected to be obtained from a sale in the open market (e.g. Chapter 5 on securities options), and
  • Capital Gains tax value (e.g. Chapter 8 Part 3 on notional loans).

Current legislation

For consistency, FA03/SCH22 ensures that all chapters within Part 7 of ITEPA now use the TCGA value, as does the related legislation on CT deductions in FA03/SCH23. However, the charge on acquisition of securities is still often the money바카라 사이트™s worth charge under ITEPA03/S62, unless an election under ITEPA03/S431 is made for the unrestricted market value to apply. In practice, there is rarely any significant difference in value between the money바카라 사이트™s worth and CGT bases. Where it is claimed that there is a significant difference Shares and Assets Valuation must be consulted.
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Restricted securities

Where restricted securities are involved, the unrestricted market value will usually be higher than the money바카라 사이트™s worth or CGT values, which take account of the restrictions.
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