For valuations at 31 March 1982 it is sometimes claimed that if
shares are held in the names of A and B jointly, the shares of each
should be valued as part of the total holding. This will normally
produce a higher value especially where the total holding confers
control.
If the shares were actually registered in the names of two
or more shareholders at 31 March 1982 (or if documentary evidence
can be produced to show that shares registered in the name of one
were in fact held as joint tenant or tenants in common) then each
individual's share is valued as part of the total holding.
Example
60 shares (out of 100) were registered in the names of A
& B at 31 March 1982. If the company was worth £100,000
the valuation of the interest of each taxpayer will be:
| Value of company | £100,000 |
| 60% thereof (less say, 15%) | £ 51,000 |
| Each one half share | £ 25,500 |
| Less discount for joint ownership (10%) | £ 22,950 |
No distinction should be made between the holdings of A and B
because only the first named was entitled to vote.
If the agents object to the discount of 10% taken they may
be informed that this method of valuation of a joint holding has
been approved by the Special Commissioners.
If a lower value results, each taxpayer's holding may be
valued as if each owned the proportion of shares in his sole name.
This instruction cannot, of course, apply to shares held in
the names of two or more trustees.
| Additional Guidance: SVM150000 |
