The primary considerations for you as a share valuer are likely
to be the strength of the facts and arguments that may be adduced
in support of a valuation adjustment and the materiality of such an
adjustment in terms of tax. However, when you are considering a
risk assessment, it is important to remember that the valuation may
be only part of a bigger picture. The case owner may have other
factors to consider e.g. the overall behaviour of a particular
taxpayer or a desire to concentrate effort into a particular
sector. A valuation may have materiality beyond the tax at risk in
the immediate case, because of wider deterrent or clarification
effects.
Care should be taken in recommending that we mount a
challenge to a valuation where to do so will be resource intensive,
unless it is clear that the challenge will discourage behaviours
that are contributing to the tax gap, or will establish valuable
legal principles.
| Additional Guidance: SVM150000 |
