The Upper Tribunal was wrong to have attributed capital values to a distinct asset of transferable goodwill as opposed to the value of the leasehold interests in two care homes for capital gains tax and stamp duty land tax valuation purposes, where the valuations were carried out in accordance with the guidance given by the Royal Institution of Chartered Surveyors in VPGA 4 on the valuation of trade related properties.

Summary

The Upper Tribunal (UT) was wrong to have attributed capital values to a distinct asset of transferable goodwill as opposed to the value of the leasehold interests in two care homes for capital gains tax (CGT) and stamp duty land tax (SDLT) valuation purposes, where the valuations were carried out in accordance with the guidance given by the Royal Institution of Chartered Surveyors (RICS) in VPGA 4 on the valuation of trade related properties.

Background

The first taxpayer )