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The introduction of the higher rate of BPR of 100%, which applies to all unquoted shares qualifying for the relief¹, means that in many cases it will not be necessary to value unquoted holdings. There may, however, still be some holdings which have to be valued, for example because the transferor has not owned them for the requisite two years before a transfer occurs, or the company is a property or investment holding company, or owns excepted assets.

For a further information on BPR generally see Division I7.1.

The purchaser in the open market² (see I8.201 onwards) of a holding carrying over 25% but less than 50% of the votes would not control the company, so they would be unable to sell the company's business, or wind up the company and realise the assets. As they would not necessarily be a director, they could not expect to receive any directors' remuneration and would not be in a position to limit the remuneration paid to the directors, or to determine the dividend