Erdal v HMRCC [2011] UKFTT 87 (TC)

Wills & Trusts Law Reports | December 2011 #115

E owned shares in a company involved in the manufacture of paper. E owned 17,131 ordinary shares and 53,476 A shares in the company. A charitable trust owned the majority shareholding in the company and the terms of the trust meant that it was unlikely that the company would ever be floated. The A shares were non-voting. The company’s articles restricted the sale or other transfer of the company shares.

The question at issue was the value of those shares as at 31 March 1982 for the purposes of Capital Gains Tax (CGT). E appealed against assessments in respect of CGT in the ...