Commissioners for Her Majesty’s Revenue and Customs v Denning and Others: CA 1 Jul 2022

The issue on this appeal relates to the valuation of two leasehold interests in care homes for the purposes of capital gains tax and stamp duty land tax, where the valuations were carried out in accordance with the guidance given by the Royal Institution of Chartered Surveyors in VPGA 4. VPGA 4 gives guidance about valuing trade related properties. Where that valuation method is applied, is the resulting figure the value of the leasehold interest, or the value of both the leasehold interest and ‘transferable goodwill’?


Lord Justice Lewison
Lord Justice Warby
Lord Justice Snowden


[2022] EWCA Civ 909




England and Wales

Capital Gains Tax, Stamp Duty, Landlord and Tenant

Updated: 07 July 2022; Ref: scu.678756