»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp regulations apply to appeals against the following

• assessments to Capital Gains Tax
• assessments to Corporation Tax on chargeable gains
• decisions on claims relating to chargeable gains.

»Ê¹ÚÌåÓýapp regulations do not apply to Income Tax. But you should try to ensure that any market values or apportionments which are determined for Income Tax purposes are consistent with

• other valuations or apportionments made for Income Tax purposes and
• any valuation or apportionment determined on the same matter for Capital Gains Tax purposes.

»Ê¹ÚÌåÓýapp regulations apply in two circumstances

• when a question of the market value or of the apportionment of any amount or value is a material question in an appeal regulation 8 allows any interested party to be joined in that appeal, see CG16430.
• where a market value or an apportionment of any amount or value has not yet been a material question in an appeal regulation 9 allows an interested party to apply to the First-tier Tribunal for a determination, see CG16570.

»Ê¹ÚÌåÓýappre are circumstances in which the regulations cannot be applied. For example, if an asset is transferred from X to a connected person Y, a valuation is put forward which gives rise to a capital loss and any alternative valuation also gives rise to a capital loss. »Ê¹ÚÌåÓýappre may be no gain arising on any other transfer between the same connected persons and so the value will not be a material question in an appeal. If neither X nor Y makes an application under paragraph 9 you will not be able to litigate the valuation dispute.