Negotiating with SAV
How Parmentier Arthur can Help You with SAV:
• If HMRC dispute a valuation, we will deal with their queries and justify our conclusions
• If you or your accountant have run into difficulties with share valuations for tax purposes, we can take on the case
Resolving these situations on the client’s preferred terms may be more of a challenge but Parmentier Arthur will always provide clear advice on the likely outcome and can take over responsibility for negotiations if needed. We also have a long history of successful achievement in negotiations with Shares and Asset Valuations based upon:
• a comprehensive understanding of the statutory framework and related case law governing fiscal open market valuations
• a detailed working knowledge of the methodologies, tendencies and general practice of SAV
• an extensive historical library of research material, and access to information sources both in the UK and abroad
• an in-depth understanding and analysis of the subject asset, necessary to optimise the valuation arguments presented in negotiations
• proven ability to represent clients’ interests in the face of HMRC scepticism or challenge
We only undertake negotiations when we believe that our involvement will be cost-effective given the tax at stake and will benefit the client’s position. Our expertise and considerable experience of dealing with SAV can make the difference between an acceptable outcome and unpalatable tax consequences.
HOW WE HELP
Need to settle a dispute over the value of a shareholding?
How much is your company worth?
Selling a minority shareholding. What is it worth?
Incorporating your sole trader business? What is the goodwill worth and what value will HMRC accept for tax purposes?
Making awards under a Management Incentive Plan? What is the value of the MIP shares for tax purposes?
Negotiations with HMRC at an impasse? Need a new perspective?
GET IN TOUCH
Possibly one of the most neglected and common areas of Pay As You Earn (“PAYE”) failure is where shares are sold by employees or ex-employees – disposals of employment-related shares.
Where not all conditions of the MoU are satisfied – is it possible to put some reliance on the principles of the MoU? If the ‘spirit’ of the MoU is satisfied, can management rely on it?
Following the introduction of the employment-related securities legislation in the Finance Act 2003, there was significant uncertainty in relation to the tax implications for management acquiring shares in venture capital (“VC”) and private equity (“PE”) backed companies.