Rules for valuing a data company when it is bought
8 US, UK and IFRS rules on valuing an acquired data company, read 28 October 2026.
Where it applies
What it governs
How it treats data and customer lists
The rule, in its words
The full board, one rule per row
Read across a row for one rule's answers, and open any of them for the quoted sentence, its statute or standard page and the read date. A "not stated" cell means the statute or standard page does not speak to that question.
| Rule | Where it applies | What it governs | How it treats data and customer lists | The rule, in its words |
|---|---|---|---|---|
| HMRC Corporate Intangibles manual | United Kingdom | tax relief on acquired intangibles | covers them as intangibles in general | Corporation Tax and the taxation of intangible assets, remediation of contaminated land… |
| HMRC Shares and Assets Valuation Manual | United Kingdom | valuing shares | not statedNot addressed in GOV.UK HMRC internal manual | How HM Revenue & Customs works out the value of shares and assets in unquoted companies… |
| IFRS 13 Fair Value Measurement | IFRS reporters | fair value in the accounts | not statedNot addressed in IFRS Foundation standard page | It applies when another Standard requires or permits fair value measurements or… |
| IFRS 3 Business Combinations | IFRS reporters | how the price is split across assets | covers them as intangibles in general | The core principles in IFRS 3 are that an acquirer measures the cost of the acquisition… |
| Section 1060 allocation in an asset acquisition | United States | how the price is split across assets | does not address them | If in connection with an applicable asset acquisition, the transferee and transferor… |
| Section 197 amortisation of acquired intangibles | United States | tax relief on acquired intangibles | names databases or customer lists as intangibles | A taxpayer shall be entitled to an amortization deduction with respect to any amortizable… |
| Section 409A reasonable valuation of private company stock | United States | valuing shares | not statedNot addressed in Code of Federal Regulations via LII | the fair market value of the stock as of a valuation date means a value determined by the… |
| Treasury regulation 1.197-2 on information bases | United States | tax relief on acquired intangibles | names databases or customer lists as intangibles | a customer-related information base is any information base that includes lists or other… |
The 32 sentences the answers come from
- HMRC Corporate Intangibles manual, GOV.UK HMRC internal manual, read 2026-10-28, Where it applies:
Corporation Tax and the taxation of intangible assets, remediation of contaminated land
- HMRC Corporate Intangibles manual, GOV.UK HMRC internal manual, read 2026-10-28, What it governs:
Corporation Tax and the taxation of intangible assets, remediation of contaminated land
- HMRC Corporate Intangibles manual, GOV.UK HMRC internal manual, read 2026-10-28, How it treats data and customer lists:
Corporation Tax and the taxation of intangible assets, remediation of contaminated land
- HMRC Corporate Intangibles manual, GOV.UK HMRC internal manual, read 2026-10-28, The rule, in its words:
Corporation Tax and the taxation of intangible assets, remediation of contaminated land, vaccines research relief and tax credits for research & development.
- HMRC Shares and Assets Valuation Manual, GOV.UK HMRC internal manual, read 2026-10-03, Where it applies:
How HM Revenue & Customs works out the value of shares and assets in unquoted companies
- HMRC Shares and Assets Valuation Manual, GOV.UK HMRC internal manual, read 2026-10-03, What it governs:
How HM Revenue & Customs works out the value of shares and assets in unquoted companies for Inheritance Tax and Capital Gains Tax purposes
- HMRC Shares and Assets Valuation Manual, GOV.UK HMRC internal manual, read 2026-10-03, How it treats data and customer lists: No answer on the statute or standard page, which ran to 12,761 characters when read on 2026-10-03.
- HMRC Shares and Assets Valuation Manual, GOV.UK HMRC internal manual, read 2026-10-03, The rule, in its words:
How HM Revenue & Customs works out the value of shares and assets in unquoted companies for Inheritance Tax and Capital Gains Tax purposes
- IFRS 13 Fair Value Measurement, IFRS Foundation standard page, read 2026-10-28, Where it applies:
IFRS 13 defines fair value, sets out a framework for measuring fair value, and requires disclosures about fair value measurements.
- IFRS 13 Fair Value Measurement, IFRS Foundation standard page, read 2026-10-28, What it governs:
IFRS 13 defines fair value, sets out a framework for measuring fair value, and requires disclosures about fair value measurements.
- IFRS 13 Fair Value Measurement, IFRS Foundation standard page, read 2026-10-28, How it treats data and customer lists: No answer on the statute or standard page, which ran to 5,360 characters when read on 2026-10-28.
- IFRS 13 Fair Value Measurement, IFRS Foundation standard page, read 2026-10-28, The rule, in its words:
It applies when another Standard requires or permits fair value measurements or disclosures about fair value measurements
- IFRS 3 Business Combinations, IFRS Foundation standard page, read 2026-10-28, Where it applies:
The core principles in IFRS 3 are that an acquirer measures the cost of the acquisition at the fair value of the consideration paid
- IFRS 3 Business Combinations, IFRS Foundation standard page, read 2026-10-28, What it governs:
allocates that cost to the acquired identifiable assets and liabilities on the basis of their fair values; allocates the rest of the cost to goodwill
- IFRS 3 Business Combinations, IFRS Foundation standard page, read 2026-10-28, How it treats data and customer lists:
allocates that cost to the acquired identifiable assets and liabilities on the basis of their fair values
- IFRS 3 Business Combinations, IFRS Foundation standard page, read 2026-10-28, The rule, in its words:
The core principles in IFRS 3 are that an acquirer measures the cost of the acquisition at the fair value of the consideration paid; allocates that cost to the acquired identifiable assets and liabilities on the basis of their fair values; allocates the rest of the cost to goodwill
- Section 1060 allocation in an asset acquisition, US Code via LII, read 2026-10-24, Where it applies:
26 U.S. Code § 1060 - Special allocation rules for certain asset acquisitions
- Section 1060 allocation in an asset acquisition, US Code via LII, read 2026-10-24, What it governs:
the consideration received for such assets shall be allocated among such assets acquired in such acquisition in the same manner as amounts are allocated to assets under section 338(b)(5)
- Section 1060 allocation in an asset acquisition, US Code via LII, read 2026-10-24, How it treats data and customer lists:
In the case of any applicable asset acquisition, for purposes of determining both
- Section 1060 allocation in an asset acquisition, US Code via LII, read 2026-10-24, The rule, in its words:
If in connection with an applicable asset acquisition, the transferee and transferor agree in writing as to the allocation of any consideration, or as to the fair market value of any of the assets, such agreement shall be binding on both the transferee and transferor
- Section 197 amortisation of acquired intangibles, US Code via LII, read 2026-10-28, Where it applies:
LII U.S. Code Title 26 Subtitle A CHAPTER 1 Subchapter B PART VI § 197
- Section 197 amortisation of acquired intangibles, US Code via LII, read 2026-10-28, What it governs:
by amortizing the adjusted basis (for purposes of determining gain) of such intangible ratably over the 15-year period beginning with the month in which such intangible was acquired
- Section 197 amortisation of acquired intangibles, US Code via LII, read 2026-10-28, How it treats data and customer lists:
any other information base (including lists or other information with respect to current or prospective customers)
- Section 197 amortisation of acquired intangibles, US Code via LII, read 2026-10-28, The rule, in its words:
A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible.
- Section 409A reasonable valuation of private company stock, Code of Federal Regulations via LII, read 2026-10-24, Where it applies:
Title 26—Internal Revenue CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
- Section 409A reasonable valuation of private company stock, Code of Federal Regulations via LII, read 2026-10-24, What it governs:
the fair market value of the stock as of a valuation date means a value determined by the reasonable application of a reasonable valuation method
- Section 409A reasonable valuation of private company stock, Code of Federal Regulations via LII, read 2026-10-24, How it treats data and customer lists: No answer on the statute or standard page, which ran to 180,106 characters when read on 2026-10-24.
- Section 409A reasonable valuation of private company stock, Code of Federal Regulations via LII, read 2026-10-24, The rule, in its words:
the fair market value of the stock as of a valuation date means a value determined by the reasonable application of a reasonable valuation method
- Treasury regulation 1.197-2 on information bases, Code of Federal Regulations via LII, read 2026-10-28, Where it applies:
Section 197 allows an amortization deduction for the capitalized costs of an amortizable section 197 intangible
- Treasury regulation 1.197-2 on information bases, Code of Federal Regulations via LII, read 2026-10-28, What it governs:
Section 197 allows an amortization deduction for the capitalized costs of an amortizable section 197 intangible
- Treasury regulation 1.197-2 on information bases, Code of Federal Regulations via LII, read 2026-10-28, How it treats data and customer lists:
Section 197 intangibles include any information base, including a customer-related information base.
- Treasury regulation 1.197-2 on information bases, Code of Federal Regulations via LII, read 2026-10-28, The rule, in its words:
a customer-related information base is any information base that includes lists or other information with respect to current or prospective customers
Method
Each rule's own US tax law, HMRC manuals and IFRS standards were read through estate-fetch and stored whole (sha256 on every row).
For every statute or standard page, four questions were answered from its own words: where it applies, what it governs, how it treats data and customer lists, the rule, in its words.
Every stated answer carries the sentence it rests on, checked against the stored text; 'not stated' means the statute or standard page read does not address the question.
A rule with several statute and standard pages reads 'varies' where they disagree.
8 rules, 8 statute and standard pages.
8 sources, with links
- 26 USC 197 (amortisable section 197 intangibles) (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
- 26 CFR 1.197-2 (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
- 26 USC 1060 (allocation in an asset acquisition) (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
- 26 CFR 1.409A-1 (reasonable valuation method) (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
- HMRC Shares and Assets Valuation Manual (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
- HMRC Corporate Intangibles Research and Development Manual (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
- IFRS 13 Fair Value Measurement (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
- IFRS 3 Business Combinations (cited for reporting; the publisher's own US tax law, HMRC manuals and IFRS standards)
Take this figure with you
8 US, UK and IFRS rules on valuing an acquired data company, read 28 October 2026.
Where it applies, by rule: United States 4 of 8, IFRS reporters 2 of 8, United Kingdom 2 of 8 (8 rules, read 28 October 2026).
What it governs, by rule: tax relief on acquired intangibles 3 of 8, how the price is split across assets 2 of 8, valuing shares 2 of 8, fair value in the accounts 1 of 8 (8 rules, read 28 October 2026).
How it treats data and customer lists, by rule: not stated 3 of 8, covers them as intangibles in general 2 of 8, names databases or customer lists as intangibles 2 of 8, does not address them 1 of 8 (8 rules, read 28 October 2026).
The rule, in its words, by rule: stated 8 of 8 (8 rules, read 28 October 2026).
To cite: "Rules for valuing a data company when it is bought", updated 2026-10-28, https://datacompanyvaluation.com/datasets/data-company-valuation-law/.
Get the CSV (32 answers, worked out 2026-10-28)