Related-party transfers

Defensible market valuations for related-party transfers of shares, units and business interests.

For family transfers, related-entity transactions and trust distributions where market value is required for tax purposes. Independent, senior-reviewed, evidence-led.

A related-party transfer valuation establishes the market value of shares, units or business interests being transferred between related parties — typically family members, related entities, trusts or controlled companies. Because related-party transactions are not at arm's length, the ATO generally requires an independent market valuation to substantiate the value applied for cost base, capital gains and stamp duty purposes.

When related-party transfer valuations matter

Related-party transfers are reviewed more closely than arm's length transactions because the parties have an incentive to set a value that suits the tax outcome rather than the market. The valuation must be independent, supportable, and document the methodology and evidence. Common scenarios include intra-family share transfers, transfers between trust and beneficiary entities, transfers between commonly-controlled companies, and transfers in estate or succession planning matters.

Independence is critical

In related-party transactions, our independence is the value we provide. Our fees are fixed at engagement. We do not adopt valuations to suit either party. Where the evidence supports a position more favourable to the client, we identify it. Where the evidence requires a conservative position, we report it. The conclusion is determined by methodology and evidence, never by either party's preference.

Methodology considerations

Related-party transfers of minority interests in private companies typically require careful consideration of discounts for lack of marketability (DLOM) and lack of control (DLOC). Where the transfer is of a controlling interest, a control premium may be appropriate. The methodology selection and the magnitude of any discount or premium are documented and reasoned in the report.

Common questions.

Can a related-party valuation be challenged by the ATO?+

Yes — related-party valuations are among the most commonly reviewed by the ATO. The defence is documentation. A defensible valuation has independent methodology selection, evidence relied upon, reasoning for discounts or premia applied, and a senior reviewer signature. Our reports are prepared to that standard.

What if both parties want a particular valuation outcome?+

We do not adopt valuations to suit either party. Our role is to identify the most supportable position the evidence allows. If either party demands a target value, we will say so and decline the engagement on those terms.

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