The Special Commissioners (Jurisdiction and Procedure) Regulations 1994

Proceedings relating to tax on chargeable gains

22.—(1) Where the market value of an asset on a particular date or the apportionment of an amount or value is a material question in any proceedings relating to tax on chargeable gains, the Tribunal hearing the proceedings shall, if so required by any party, record in its decision in principle or final determination that market value or apportionment.

(2) The final determination on an appeal of the market value of an asset on a particular date or of the apportionment of any amount or value may be proved in any proceedings relating to tax on chargeable gains by a certificate stating the material particulars signed by—

(a)an inspector where the appeal was settled by agreement, or

(b)the Clerk where the Special Commissioners determined the appeal, or

(c)the clerk or registrar of another tribunal where the material question was determined by that other tribunal in accordance with section 47 or 47B of the Management Act(1) or section 222(4A) of the Inheritance Tax Act 1984(2),

and a document purporting to be such a certificate may be received in evidence in any such proceedings without further proof.

(3) In this regulation the expression “final determination on an appeal” shall be construed in accordance with regulation 11(2) of the Capital Gains Tax Regulations 1967(3), and the expression “material question in any proceedings” shall be construed in accordance with regulation 15(a) of those Regulations.