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SAS Marks v HMRC

In SAS Marks v HMRC (TC01086 – 20 April) a company director (M) owned the entire share capital of two companies (a UK company and an overseas company) at 31 March 1982. He disposed of some of the shares between 2000 and 2004.

HMRC formed the opinion that M’s returns were incorrect as they overestimated the value of the shares at 31 March 1982. They issued amendments to M’s self-assessments valuing the two companies at £3 100 000 at that date. M appealed contending that the companies had had a total value of £8 425 000.

The First-tier Tribunal reviewed the evidence in detail and allowed the appeal in part valuing the UK company at £3 709 000 and the overseas company at £443 000.

Why it matters: This is a specialised area but the case is...

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