Paragraph 45 of Schedule 10 to the Finance Act 2003, which applies only where an appeal has been notified to the First-tier Tribunal, requires any “question of the market value of the subject matter of the land transaction” to be transferred to the Upper Tribunal (Lands Chamber). What is transferred is only that question. The appeal itself, including all other issues of fact and law, remains with the First-tier Tribunal. Paragraph 45 simply requires questions of valuation to be referred to the Lands Chamber. It says nothing about the timing of a reference. The clear intention is that issues of valuation should be dealt with by specialists in that area, with all other issues being dealt with by the First-tier Tribunal. The question of when the First-tier Tribunal should refer an issue of valuation is a case management decision for the First-tier Tribunal and, as with other case management decisions, it should exercise its powers in accordance with the overriding objective to deal with cases fairly and justly, having regard among other things to the need to deal with cases in a proportionate manner and to the need to avoid unnecessary delay. In some cases it may be clear that the most efficient and effective approach is to refer the question of market value at a relatively early stage. This will most obviously be the case where the parties are agreed that value is the only issue, or only material issue, that arises. There is no format for the terms of a reference under paragraph 45. In some circumstances it might be straightforward: the Upper Tribunal (Lands Chamber) may simply be asked to value a particular parcel of land as at a specified date. But where there are transactions which are potentially relevant to determining market value and there is an actual or potential dispute about their terms or about their legal (including tax) effect, it will be for the First-tier Tribunal, not the Upper Tribunal (Lands Chamber), to determine any such dispute, and it will need to incorporate any relevant findings into the reference (paras 32, 35, 39–40, 57, 58).