[2024] UKUT 00301 (LC)

The basis of valuation is not in dispute. The relevant legislation governing the valuation is Part 3 of the Finance Act 2013. The value of a dwelling for the purposes of ATED is the ‘market value’ of the property on the relevant day (s.102(1)).

It is agreed that the relevant day, and thus the valuation date in this case, is 1 April 2017.

S.98(8) of the 2013 Act provides that ‘market value’ is to be determined as defined by s.272(1) of the Taxation of Chargeable Gains Act 1992 as:

“…in relation to any assets…the price which those assets might reasonably be expected to fetch on a sale in the open market".