I have submitted separate CG34’s for husband and wife following sale of a jointly owned property, which we revalued for non-resident CGT at the 5 April 2015 value.
HMRC have now made an adjustment of 10% of each share, saying this is in line with established practice to reflect the fact that a share in the leasehold interest has been valued. I was of the opinion that the 10% reduction only related to jointly owned property in probate valuations to reflect that the surviving owner had a continued right of occupation.
Are the correct in applying it to CGT valuations and if so, surely it should be 10% over the whole value of the property and not 10% for each individual half share?
I believe the Revenue are correct as what they are valuing are the individual half shares of the property not a half of the whole. This is to reflect the value of a half share in the open market. There are no related property rules for CGT as there are for IHT.
As to the percentage whether you take 10% of the whole and halve it or take 10% off a half the end result should be the same