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Negligible Value Claim Was Validly Made

By Mark McLaughlin, October 2017
A negligible value claim submitted online to HMRC immediately prior to a disposal of shares, which did not specifically make reference to the claim but included an application to reduce his payments on account in an amount equivalent to the share loss relief being claimed, was held to be valid. 

The appellant’s tax return for 2010/11 declared income of £325,863, less losses of £261,735, which included £194,500 in respect of a negligible value claim (NVC) and share loss relief claim. The NVC related to losses suffered by the appellant on his disposal of shares in a company following its insolvency in 2010.

The appellant asserted that on 12 May 2011, he emailed HM Revenue and Customs (HMRC) (from his solicitor’s office, where he was arranging the disposal of his shares in the company to a co-shareholder) via the HMRC website, lodging a claim for share loss relief. The appellant did not
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