The business valuation referral guide for accountants.
For accountants and tax agents: the client events that require a formal valuation, the APES 225 independence problem with doing it in-house, and a standard briefing pack that makes referral fast.
Accountants refer clients for a formal business valuation when a tax or transaction event fixes a consequence to market value — small business CGT concessions, restructures, Division 7A transactions, buy-sell events, estates and employee share schemes. APES 225 makes valuing your own client structurally problematic. Prismi provides independent, evidence-led valuations built for accountant referral, with fixed fees quoted at engagement, defined turnaround times and a standard briefing pack.
When a client event needs a formal valuation — and when it doesn't
Most compliance work never needs a valuation. The trigger is a client event where tax law or a binding document fixes a consequence to market value: a small business CGT concession claim where the eligibility tests turn on market values (Div 152 ITAA 1997), a restructure rollover (Subdiv 328-G), a non-arm's-length transfer where market value substitution applies (s 116-30), a Division 7A transaction, a buy-sell event under a shareholders' agreement, a deceased estate, or an employee share scheme issue. In each case, the number that goes into the return, the deed or the minutes needs documented evidence behind it. An accountant's estimate or an industry rule of thumb is precisely the kind of position that does not hold up if the ATO asks how the value was reached — the ATO's market valuation guidance expects methodology, evidence and reasoning, not a multiple noted on the workpaper. The standard is market value in the Spencer sense: what a willing but not anxious buyer would pay a willing but not anxious seller.
The trigger table: client events that require an independent valuation
- ·Small business CGT concessions (Div 152 ITAA 1997) — the maximum net asset value test (s 152-15) and the active asset test (s 152-35) both depend on market values; the concession claim is only as strong as the valuation evidence behind it
- ·Restructures and rollovers (Subdiv 328-G) — the small business restructure rollover requires market-value evidence at the transfer date to support the position taken
- ·Related-party and non-arm's-length transfers — s 116-30 substitutes market value for actual proceeds, so the value in the transfer documents needs independent support
- ·Division 7A (ITAA 1936) — transfers of assets from a private company to shareholders or their associates are treated as payments at market value; an unsupported value creates deemed dividend exposure
- ·Buy-sell and shareholder exit events — shareholders' agreements, insurance funding reviews and exiting-partner buyouts all need a value both sides can rely on
- ·Deceased estates and succession — date-of-death and historical acquisition values, frequently retrospective, where the estate and the beneficiaries need an independent number
- ·Employee share schemes (ESS) — the market value of shares or options, at grant and at any deferred taxing point, drives the employee's tax position and the scheme documentation
Why valuing your own client puts your firm at risk
APES 225 Valuation Services applies whenever a member in public practice provides a valuation service, and it requires objectivity and professional competence. The problem with valuing your own client is structural, not personal. The firm that prepared the financial statements is now opining on a value derived from them — a self-review threat. The firm that lodges the return benefits professionally from the concession being available — an advocacy threat. And if the ATO reviews the claim, the first question asked of a valuation prepared by the tax agent who lodged the return is the independence of the valuer. Referring the valuation out resolves all three at once: the accountant keeps the tax application, the independent valuer signs the value with an independence statement, and the file shows a clean separation between the person who determined the value and the person who used it.
The standard briefing pack: what to send with a referral
A referral is faster and cheaper for the client when the brief is complete. The pack below is what we need to quote a fixed fee and start the engagement without back-and-forth — most of it already sits in your working papers.
- ·The purpose and provision — Div 152 concession claim, Subdiv 328-G rollover, Div 7A transfer, buy-sell, estate or ESS — because purpose drives methodology and report scope
- ·The valuation date or dates, including whether any date is retrospective
- ·Entity structure — ASIC extract or trust deed, shareholder or unit-holder register, group structure diagram where applicable
- ·Financial statements for the last 3–5 years plus current year-to-date management accounts
- ·The proposed transaction terms and any related-party transactions on foot
- ·The add-back schedule with supporting evidence, where one exists
- ·The deadline that matters — lodgement date, deed execution date, probate timeline
- ·The contact protocol — whether the client deals with us directly or everything runs through your office
Fixed fees and turnaround times you can quote in the client meeting
Fees are fixed at engagement and are never contingent on the outcome — the quote you pass on in the client meeting is the fee. Turnaround runs from the document completeness check, not from first contact.
- ·Essential — from $1,495 + GST, delivered in 10–14 business days
- ·Comprehensive — from $3,995 + GST, delivered in 15–25 business days
- ·Defensible Valuation File — from $8,995 + GST, delivered in 25–35 business days
- ·Valuation Range & Scenario Review — premium engagement, scoped and quoted on enquiry
- ·Retrospective valuations — +$495 per historical valuation date; additional entities $750 each; rush delivery +30% of the base fee, subject to capacity
Which tier to recommend for which matter
Essential suits straightforward single-entity matters where a concise, supportable value is needed — a simple Division 7A asset transfer, an internal buy-sell funding review. Comprehensive is the default recommendation for Div 152 concession claims, Subdiv 328-G restructures and live buy-sell events: multiple methodologies tested, a supportable range identified, and the concluded position reasoned in the report. The Defensible Valuation File is for matters where review or dispute is a realistic prospect — high-value concession claims, contested estates, positions the ATO is likely to examine — and includes the full working-file build designed to be handed over if questions come. The Valuation Range & Scenario Review suits clients planning ahead of a transaction rather than reporting one. Estates and other historical dates attract the retrospective surcharge; group structures are quoted per additional entity.
How the referral runs in practice — including co-branding
Send the briefing pack; we run a conflict check and return a fixed-fee quote. The engagement letter can go to the client or to your firm, and you choose the contact protocol — many referring accountants remain the sole client contact from start to finish. Draft reports go to you first for a factual-accuracy review; the conclusion itself is not negotiable, because the methodology and evidence determine the position, and if a client wants a target number we will say so and decline the engagement on those terms. On presentation: the report can be co-branded for delivery through your firm, or delivered entirely within your client relationship, but the signature, the independence statement and responsibility for the conclusion always remain Prismi's — that separation is what makes the referral worth making. Every report is senior-reviewer signed and the full working file is retained. We prepare independent valuations only: no tax agent services, no compliance work, no advice on applying the concessions, and no interest in your client beyond the valuation engagement. The tax and legal application stays with you.
Common questions.
Can an accountant value their own client's business under APES 225?+
APES 225 does not prohibit it outright — a member with the competence and objectivity to perform the valuation service may do so. In practice, the self-review threat (the firm valuing figures it prepared) and the advocacy threat (the firm benefiting from the tax outcome) are difficult to answer if the valuation is later reviewed. Referring the valuation to an independent specialist removes both threats and keeps the file clean.
How much does a business valuation cost for a Div 152 or Div 7A matter?+
Prismi fees are fixed at engagement: Essential from $1,495 + GST, Comprehensive from $3,995 + GST, and the Defensible Valuation File from $8,995 + GST. Most Div 152 concession claims sit in the Comprehensive tier. Retrospective dates add $495 per historical date and additional entities $750 each.
Does Prismi advise on the small business CGT concessions?+
No. Prismi prepares independent valuations only — we are not a registered tax agent and do not provide tax, legal or financial advice. The report provides the market value evidence; the accountant applies Div 152, Div 7A or the relevant provision to it. That division of roles is deliberate — it is what preserves the independence of the valuation.
Can the valuation report be white-labelled with my firm's branding?+
Delivery can be co-branded or run entirely through your client relationship, but the report is always signed by Prismi with an independence statement, and responsibility for the conclusion remains ours. A report white-labelled to the point where the referring firm appears to be the valuer would defeat the independence the referral is designed to create.
Will referring a client to a valuation firm risk the client relationship?+
The workflow is built so it does not. You choose the contact protocol, you can remain the sole client contact, and drafts come to you first. Prismi does not provide compliance, advisory or tax agent services, so there is nothing to cross-sell — the engagement starts and ends with the valuation.
