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(former Schedule F)
HMRC may seek the assistance of DVs in cases arising out of company distributions as defined in s.209 ICTA 1988. Such references will be clearly marked as being required in order to quantify a liability under the distribution provisions. For Income Tax, distribution provisions are in Part 4, Chapter 3, The Income Tax (Trading and Other Income) Act 2005. HMRC may also seek the assistance of DVs in connection with the establishment of the company's liability under s.419, ICTA 1988; and, more rarely, may require assistance in connection with the establishment of liability under s.418 (see 1.61 below).
In cases arising out of s.209, ICTA 1988, where a market valuation is required the DV's valuation should be on the basis of normal open market value for Revenue purposes (see Section 7).
Exceptionally in a case arising out of a distribution within s.418, ICTA 1988 where a property has been let by a close company (s.414 and s.416) to a participator (s.417) at a rent which is apparently below market rental level, HMRC may ask the DV to provide an opinion of the "annual value" (as defined in s.837, ICTA 1988 - see paragraph 1.54).