Taxation of Chargeable Gains Act 1992 section 273

Unquoted shares and securities

Section 273 establishes the information assumptions that apply when valuing shares and securities not listed on a recognised stock exchange for capital gains tax purposes.

  • The section applies to shares and securities that are not listed on a recognised stock exchange at the time their market value needs to be determined for chargeable gains purposes.
  • When determining market value under the general valuation rule in section 272(1), a key assumption is made about the information available to a hypothetical buyer.
  • The assumption is that any prospective purchaser in the hypothetical open market has access to all the information a prudent buyer would reasonably require if purchasing the asset by private treaty at arm's length from a willing vendor.
  • This information assumption supplements the standard open market valuation approach and ensures that the hypothetical buyer is not disadvantaged by the lack of publicly available data that would typically exist for listed shares.

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