We recently resolved a long running valuation case for a client involving the disposal by four shareholders of 100% of their company (two x 45% shareholders and two x 5% shareholders) to their sons.

Naturally, the shares needed to be passed at market value as they were being transferred to connected parties. 

From the outset, HMRC considered that the share values should be heavily discounted which we refuted on the basis that 100% of the shareholding was to be disposed of.  Nevertheless, HMRC would not accept this as the basis for displacing their view.