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Chifley Holdings Ltd (BVI) v HMRC [electronic resource]

Language: English Publication details: Upper Tribunal (Lands Chamber) [2024] UKUT 00301 25 September 2024Subject(s): Online resources: Summary: [2024] UKUT 00301 (LC). An appeal decision on the valuation of a multi-million-pound West End London home for the purposes of the Annual Tax on Enveloped Dwellings (‘ATED’), an annual tax payable by companies that own UK residential property worth more than £500k. In finding that the property was worth more than £10m as argued by HMRC, the Upper Tribunal considered the relevance of and weight to be given to post-valuation date evidence, holding that while events after the valuation date which could not have been known to the valuer or hypothetical buyer should not be taken into account, post-transaction sales can be used to inform the valuer as to the state of the market at the time of the valuation.

[2024] UKUT 00301 (LC). An appeal decision on the valuation of a multi-million-pound West End London home for the purposes of the Annual Tax on Enveloped Dwellings (‘ATED’), an annual tax payable by companies that own UK residential property worth more than £500k.

In finding that the property was worth more than £10m as argued by HMRC, the Upper Tribunal considered the relevance of and weight to be given to post-valuation date evidence, holding that while events after the valuation date which could not have been known to the valuer or hypothetical buyer should not be taken into account, post-transaction sales can be used to inform the valuer as to the state of the market at the time of the valuation.