BIM33115 - Stock: valuation: the valuation bases
Acceptable valuation bases
There are two acceptable valuation bases for stock and work in progress as follows:
- the lower of cost or net realisable value (CIR v Cock Russell
& Co Ltd [1949] 29TC387),
BIM33135,
- mark to market, BIM33160.
All other bases are not acceptable for tax purposes.
Long term contracts are valued on a basis that brings in a
profit/loss element,
BIM33025.
The valuation included in financial statements prepared in
accordance with generally accepted accounting practice should be
accepted provided that:
- it reflects the correct application of the principles of normal accountancy,
and
- the method pays sufficient regard to the facts,
and
- the basis does not violate the taxing statutes as interpreted by the courts.
Following the decisions in Ostime v Duple Motor Bodies Ltd
[1961] 39TC537, and Threlfall v Jones [1993] 66TC77 the basis of
valuation of stock and long term contracts adopted in accounts
should be accepted as valid for tax purposes. The accountancy
treatment of stock is set out in SSAP9 - Stocks and long term
contracts.
Accurate provisions for foreseen losses on long term
contracts made in accordance with correct accountancy practice are
deductible for tax purposes following the decision in Herbert Smith
v Honour [1999] 72TC130. (SP3/90 was the Statement of Practice
dealing with our view of the law on long-term contracts, - it was
withdrawn on 20 July 1999 for all accounting periods open at that
date.)
The need for the basis of valuation to reflect the actual
facts was emphasised in Anaconda American Brass Co Ltd v
Minister of National Revenue, 1956 2WLR31 (
BIM33120) - see pages 116-7 of Threlfall
v Jones 66TC77. A valuation that pays insufficient attention to the
facts will not be acceptable even if it is made on a recognised
basis. In some circumstances there may be more than one acceptable
method of computing the value of stock but the valuation policy
should be consistent unless the reasons for change outweigh the
need for consistency.
Alternative acceptable approaches
In some situations there may be two or more acceptable
approaches to valuing work-in- progress. HMRC do not have the right
to substitute one basis that is valid for tax purposes for another
such basis. In Pearce v Woodall-Duckham Ltd [1978] 51TC271 for
example Templeman J (later Lord Templeman) said:
'the company was entitled to produce accounts
based on its on- cost method prior to 1969. The company was
entitled, but not bound, to produce accounts for 1969 and
subsequent years by the accrued profit method. The change was made
for sound commercial reasons.' Equally the HMRC view is that
where a basis which is valid for tax purposes has been adopted in a
taxpayer’s accounts the taxpayer does not have the right to
adopt a different basis in computing the profits figure to be
entered on his tax return.
In Johnston v Britannia Airways Ltd [1994] 67TC99 Knox J
said:
'Which of the three ways in which the
attribution of cost to a period or periods of accounting is adopted
is, in my view, essentially a matter of accountancy judgement, and
I am quite unable to detect any legal basis for excluding any of
them.' Although in that case the Special Commissioners had
expressed a preference for the method actually adopted by the
taxpayer that was not the basis of their decision.
