Published on 01 Apr 14
by "THE TAX SPECIALIST" JOURNAL ARTICLE
Marriage value arises from the marriage or combination of different assets. The application of the marriage value concept is complex and has direct tax implications by virtue of the way in which it affects the assessed value of specialised in situ assets in “land rich” cases. It also has implications in capital gains tax. Depending on the facts of the case, marriage value can be either some form of special value (driven by tax optimisation) which is separate from the market value of the assets being valued, or embedded in the value of the portfolio of existing specialised in situ assets, or reflected in the economic value of goodwill, which are distinct from the value of the existing specialised in situ assets.
This article aims to develop a conceptual framework that will provide some guidance when dealing with issues associated with marriage value in a given case.
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