Ownership & Share Transitions
Preparing Evidence for an EMI Valuation Submission
Prepare the records and share-rights evidence for a purpose-specific EMI valuation. Agreement and timing are not guaranteed.
Written by Tony Vaughan·Last reviewed: July 2026
This supporting guide focuses on preparing an evidence pack rather than providing a second EMI service page. Read the canonical EMI share valuation resource for AMV, UMV, current grant-date rules, exceptions and the formal enquiry route. An HMRC valuation agreement does not approve every EMI condition or guarantee tax treatment.
AMV versus UMV explained
AMV takes account of relevant restrictions and forfeiture risk; UMV disregards them for the statutory valuation. The exercise-price comparison and option-limit tests have distinct uses. Current and historic grant-date thresholds and the specified Northern Ireland exception are explained in the EMI resource.
There is no standard AMV discount. Provide the actual articles, shareholder agreements and proposed option terms so the adviser can identify the relevant rights, restrictions and valuation basis.
Preparing the SAV evidence pack
The VAL231 application and supporting evidence should identify company background, the relevant shares and rights, financial information, proposed values and reasoning. HMRC SAV may ask questions. No particular presentation or method guarantees agreement; follow the current form instructions.
The timetable
Do not assume a standard HMRC response time. The agreed valuation normally covers 90 days from agreement, conditional on no value-affecting change before grant. HMRC calls for a fresh VAL231 if options are not granted within the period. Record the agreement and grant dates separately.
Common mistakes to avoid
Disclose current trading, relevant investment or sale discussions and the actual share terms. Do not invent a restriction discount or apply an unexplained sector multiple. Record uncertainties and why evidence is relevant; AMV and UMV need case-specific analysis rather than an assumed difference.
When the share class structure matters
Where the company has multiple share classes with different rights, the EMI shares must be valued specifically. Often a separate growth-share class is used for EMI to manage the AMV and align employee returns with future value creation. The valuation must reflect the specific economic rights of the EMI shares, not the rights of ordinary shares.
Post-grant compliance
Grant notification, annual reporting and monitoring later events are separate compliance responsibilities. Use current HMRC instructions and the relevant grant-date rules; do not assume a historic deadline applies to every grant. Agree explicitly which tasks are included in the adviser engagement.
Key takeaways
- EMI requires both AMV (with restrictions) and UMV (without).
- Follow current VAL231 instructions and provide relevant share and financial evidence.
- Agreement covers a conditional 90 days from agreement; reassess changes and expiry.
- Professional evidence does not guarantee agreement, timing or wider EMI eligibility.
Work it through on your own figures
- Get an indicative view of share value
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Frequently asked questions
What is the difference between AMV and UMV?
AMV considers relevant restrictions and forfeiture risk; UMV disregards them for the statutory exercise. Where restrictions affect value, HMRC requests both. No standard percentage difference applies.
How long does HMRC take to agree an EMI valuation?
This guide does not guarantee a response time. HMRC may request further information; discuss the planned grant and allow for queries.
How long is an agreed EMI valuation valid?
90 days from agreement, subject to no value-affecting change before grant. HMRC guidance calls for a fresh VAL231 if options are not granted within the period.
What does an EMI valuation cost?
Scope, fees, timing and whether submission or query support is included must be agreed before engagement. There is no universal price or included service package.
Can I do an EMI valuation in-house?
Advance agreement is not mandatory, but values must be supportable and all applicable conditions assessed. Do not treat a spreadsheet or the free business calculator as an EMI valuation.
What happens if HMRC rejects my valuation?
HMRC may request evidence or propose different values. Confirm the agreed scope for handling queries; no outcome, acceptance rate or response time is guaranteed.
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