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.

8 rules Rules on the register 8 statute and standard pages checked, 28 Oct 2026
4 of 8 Where it applies: United States the commonest of 3 answers
3 of 8 What it governs: tax relief on acquired intangibles the commonest of 4 answers
3 of 8 How it treats data and customer lists: not stated the commonest of 4 answers
8 of 8 The rule, in its words: stated rules whose statute and standard pages state it, with the quote below
8 Statute and standard pages on file 8 named; each answer carries its date and a hash

Where it applies

  1. United States4 rules
  2. IFRS reporters2 rules
  3. United Kingdom2 rules
8 rules, each counted once.
Counts
RowValue
United States4 rules
IFRS reporters2 rules
United Kingdom2 rules

What it governs

  1. tax relief on acquired intangibles3 rules
  2. how the price is split across assets2 rules
  3. valuing shares2 rules
  4. fair value in the accounts1 rule
8 rules, each counted once.
Counts
RowValue
tax relief on acquired intangibles3 rules
how the price is split across assets2 rules
valuing shares2 rules
fair value in the accounts1 rule

How it treats data and customer lists

  1. not stated3 rules
  2. covers them as intangibles in general2 rules
  3. names databases or customer lists as intangibles2 rules
  4. does not address them1 rule
8 rules, each counted once.
Counts
RowValue
not stated3 rules
covers them as intangibles in general2 rules
names databases or customer lists as intangibles2 rules
does not address them1 rule

The rule, in its words

  1. stated8 rules
8 rules, each counted once.
Counts
RowValue
stated8 rules

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.

RuleWhere it appliesWhat it governsHow it treats data and customer listsThe rule, in its words
HMRC Corporate Intangibles manual
United Kingdom

Corporation Tax and the taxation of intangible assets, remediation of contaminated land GOV.UK HMRC internal manual

tax relief on acquired intangibles

Corporation Tax and the taxation of intangible assets, remediation of contaminated land GOV.UK HMRC internal manual

covers them as intangibles in general

Corporation Tax and the taxation of intangible assets, remediation of contaminated land GOV.UK HMRC internal manual

Corporation Tax and the taxation of intangible assets, remediation of contaminated land…

Corporation Tax and the taxation of intangible assets, remediation of contaminated land, vaccines research relief and tax credits for research & development. GOV.UK HMRC internal manual

HMRC Shares and Assets Valuation Manual
United Kingdom

How HM Revenue & Customs works out the value of shares and assets in unquoted companies GOV.UK HMRC internal manual

valuing shares

How HM Revenue & Customs works out the value of shares and assets in unquoted companies for Inheritance Tax and Capital Gains Tax purposes GOV.UK HMRC internal manual

not stated

Not addressed in GOV.UK HMRC internal manual

How HM Revenue & Customs works out the value of shares and assets in unquoted companies…

How HM Revenue & Customs works out the value of shares and assets in unquoted companies for Inheritance Tax and Capital Gains Tax purposes GOV.UK HMRC internal manual

IFRS 13 Fair Value Measurement
IFRS reporters

IFRS 13 defines fair value, sets out a framework for measuring fair value, and requires disclosures about fair value measurements. IFRS Foundation standard page

fair value in the accounts

IFRS 13 defines fair value, sets out a framework for measuring fair value, and requires disclosures about fair value measurements. IFRS Foundation standard page

not stated

Not addressed in IFRS Foundation standard page

It applies when another Standard requires or permits fair value measurements or…

It applies when another Standard requires or permits fair value measurements or disclosures about fair value measurements IFRS Foundation standard page

IFRS 3 Business Combinations
IFRS reporters

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 Foundation standard page

how the price is split across assets

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 Foundation standard page

covers them as intangibles in general

allocates that cost to the acquired identifiable assets and liabilities on the basis of their fair values IFRS Foundation standard page

The core principles in IFRS 3 are that an acquirer measures the cost of the acquisition…

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 IFRS Foundation standard page

Section 1060 allocation in an asset acquisition
United States

26 U.S. Code § 1060 - Special allocation rules for certain asset acquisitions US Code via LII

how the price is split across assets

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) US Code via LII

does not address them

In the case of any applicable asset acquisition, for purposes of determining both US Code via LII

If in connection with an applicable asset acquisition, the transferee and transferor…

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 US Code via LII

Section 197 amortisation of acquired intangibles
United States

LII U.S. Code Title 26 Subtitle A CHAPTER 1 Subchapter B PART VI § 197 US Code via LII

tax relief on acquired intangibles

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 US Code via LII

names databases or customer lists as intangibles

any other information base (including lists or other information with respect to current or prospective customers) US Code via LII

A taxpayer shall be entitled to an amortization deduction with respect to any amortizable…

A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. US Code via LII

Section 409A reasonable valuation of private company stock
United States

Title 26—Internal Revenue CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY Code of Federal Regulations via LII

valuing shares

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 Code of Federal Regulations via LII

not stated

Not 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…

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 Code of Federal Regulations via LII

Treasury regulation 1.197-2 on information bases
United States

Section 197 allows an amortization deduction for the capitalized costs of an amortizable section 197 intangible Code of Federal Regulations via LII

tax relief on acquired intangibles

Section 197 allows an amortization deduction for the capitalized costs of an amortizable section 197 intangible Code of Federal Regulations via LII

names databases or customer lists as intangibles

Section 197 intangibles include any information base, including a customer-related information base. Code of Federal Regulations via LII

a customer-related information base is any information base that includes lists or other…

a customer-related information base is any information base that includes lists or other information with respect to current or prospective customers Code of Federal Regulations via LII

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
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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/.

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8 US, UK and IFRS rules on valuing an acquired data company, read 28 October 2026.
Rules for valuing a data company when it is bought, datacompanyvaluation.com

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