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Contents

Official guidance
Capital Gains Manual

CG27000C · Partnerships

  • CG27000 · Contents: Statutory rules, Statements of Practice and SA Returns
  • CG27020 · Partnerships, limited partnerships and limited liability partnerships
  • CG27050 · Limited liability partnerships- statutory rules
  • CG27070 · Limited Liability partnerships: transfer of a partnership business to a LLP
  • CG27080 · Partnerships, limited partnerships and limited liability partnerships: Limited liability partnerships: roll-over relief and gifts hold-over relief
  • CG27100 · Partners
  • CG27150 · Statement of practice D12: summary
  • CG27170 · Statement of practice D12: full text
  • CG27200 · Partnership assets
  • CG27220 · Calculating a fractional interest in a partnership asset
  • CG27250 · Valuation of a partner's fractional interest in a partnership asset: SP D12:
  • CG27300 · Fractional interests in partnership assets acquired in stage: SPD12.
  • CG27350 · Disposals of partnership assets: SP D12
  • CG27400 · Partnership assets divided in kind among the partners: SP D12
  • CG27500 · Changes in fractional interests in partnership assets: SP D12: Sections 4, 6 and 7
  • CG27540 · Changes in fractional interests in partnership assets: examples
  • CG27640 · Partners joining or leaving a partnership: examples
  • CG27700 · Partnership mergers: SP D12: Section 10
  • CG27800 · Transfers not at arm’s length and connected persons rules: SP D12: Section 8
  • CG27900 · Transfer of an asset to a partnership: SP D12: Section 5
  • CG27940 · Example 1: transfer of an asset at market value
  • CG28000 · Partnership goodwill and negligible value claims
  • CG28100 · Rebasing of interests in partnership assets held at 31 March 1982
  • CG28140 · Rebasing: changes in partnership sharing ratios: SP1/89
  • CG28230 · Rebasing: examples: FA 2008 rules: change in partnership sharing ratios on or after 6 April 2008 - FA 2008 rebasing rules
  • CG28290 · Rebasing: deferred gains: SP1/89
  • CG28300 · Indexation allowance
  • CG28400 · Partnership annuities: SP D12
  • CG28500 · Transfer of a partnership business and capital gains reliefs: entrepreneurs’ relief, “roll-over” relief and gift “holdover” relief: SP D12: Section 14
  1. Partnerships: contents
  2. Partnerships: Valuation of a partner's fractional interest in a partnership asset: SP D12:

CG27250 | Partnerships: Valuation of a partner's fractional interest in a partnership asset: SP D12:

From HM Revenue & Customs · Capital Gains Manual

Section 1 of SP D12 explains that the market value of a partner’s fractional interest in a partnership asset will be a fraction of the value of the entirety of the partnership's interest in the asset without any discount for the size of the partner's interest.

A valuation of a partner's fractional interest in an asset can be obtained from:

  • the Valuation Office – for land or buildings in the UK, or

  • Shares and Assets Valuation – for unquoted shares or securities, partnership goodwill, see CG68300, or other intangible assets.

When obtaining a valuation of a partner's fractional interest in an asset you must make it clear that the special partnership valuation basis is required and that the normal rules for discounting do not apply.

Example

A partnership between Y and Z owns 70% of the issued share capital of X Ltd.

The partners’ interests in partnership assets are:

  • Y = 80%

  • Z = 20%

The market value of the 70% shareholding as at 31 December accounting for the premium value attributable to the partnership’s controlling interest in X Ltd was £10,000.

The market values of the partners’ interests in the 70% shareholding in X Ltd as at 31 December were:

  • Y - £10,000 x 80% = £8,000

  • Z - £10,000 x 20% = £2,000

Note that the market value is apportioned by reference to the partners’ fractional interests. No premium value is attributed to Y’s larger partnership interest, nor is any reduction in value attributed to Z’s minority partnership interest.

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