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HMRC internal manual

Capital Gains Manual

Death and Personal Representatives: Valuation of assets at date of death and associated liaison with Specialist PT-IHT: Ascertained values: Valuation of assets at death: only one valuation for IHT and CGT or CTCG

The value of an asset at the date of death may be needed in order to compute the Inheritance Tax liability of the estate, see CG30300 and Appendix 4. It may also be required for Capital Gains (CGT or CTCG) purposes as an acquisition cost if either the personal representatives or the legatee subsequently dispose of the asset. Because the valuation is used in arriving at the liability on death under both taxes it is important to ensure that the same value is used in dealing with each tax. Also it is important that arguments about the value of the asset are not duplicated. This result is achieved by TCGA92/S274. This provides that where

  • the value of an asset is required for the purposes of both capital gains and inheritance tax

and

  • that value has been `ascertained’ for the purposes of Inheritance Tax

that value is also to be used as the acquisition cost for Capital Gains purposes, except in certain cases where CG32238 (extra nil-rate bands) applies.