Capital Acquisitions Tax Consolidation Act 2003 section 27

Market value of certain shares in private companies

Section 27 sets out special rules for valuing shares in private companies where the company is controlled by the beneficiary (donee or successor), ensuring that shares forming part of a controlling group are valued as a proportion of the group rather than as a minority holding.

• Where a beneficiary and connected persons together control a private company, each share is valued as a proportionate part of the entire controlling group of shares, not as a standalone minority holding.
• A "group of shares" includes shares held by the beneficiary, relatives, civil partners and their children or grandchildren, nominees, and trustees of relevant settlements.
• A private company is one controlled by five or fewer persons (treating related persons as a single person) and which is not a quoted company.
• Control means having a majority of voting power, board powers, entitlement to more than half the dividends, or holding 50% or more of the nominal share capital.