This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our Cookie Policy.
Analytics

Tools which collect anonymous data to enable us to see how visitors use our site and how it performs. We use this to improve our products, services and user experience.

Essential

Tools that enable essential services and functionality, including identity verification, service continuity and site security.

Where Taxpayers and Advisers Meet

Private Co Shares and Discounts

Rows Mum
Posts:12
Joined:Thu Oct 18, 2012 5:39 pm
Private Co Shares and Discounts

Postby Rows Mum » Wed Nov 27, 2013 10:23 pm

Would appreciate any advice anyone has with regard to discounts on private company shares. Private property investment co, small number of shareholders - family members and a couple of trusts, the beneficiaries of which are certain family members. The trustees of one of the trusts (trust A) hold 27% of the issued share capital. Co has been valued on a net asset position and the trustees of Trust A have been advised by the accountant that the value of their holding is simply 27% of the total Co value.

The Trust will shortly have a 10 year charge, and I wonder if, in this context, there is scope for applying a discount to the accountant's figure? The potential IHT is substantial, so looking at how we might sensibly batter this down.

Has anyone successfully argued for a discount in similar circumstances?

Many thanks in advance

pawncob
Posts:5099
Joined:Wed Aug 06, 2008 4:06 pm
Location:West Sussex

Re: Private Co Shares and Discounts

Postby pawncob » Thu Nov 28, 2013 11:57 am

You could argue that the number of potential purchasers is restricted because of the large shareholding, and therefor it's not an open market.
Watch out for the counterargument that a 27% holding only leaves 73% in other hands (below the critical 75% level).
With a pinch of salt take what I say, but don't exceed your RDA


Return to “Inheritance Tax, IHT, Trusts & Estates, Capital Taxes”