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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.

Holdings carrying 25% of the votes or less differ from larger minority holdings in that the holder cannot block a special resolution, his votes have less influence, and he stands less chance of acquiring control by purchasing more shares. He will be much more concerned with the dividend prospects, and less with earnings or assets.

A higher yield (or lower price earnings ratio) will normally be required to discount these disadvantages,