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HMRC internal manual

Inheritance Tax Manual

Ascertained values: introduction

Where the value of property - most often land and buildings - has been established for Inheritance Tax purposes, that valuation is binding on both sides and must be adopted by both HMRC and the beneficiary in determining the latter’s acquisition cost for Capital Gains Tax purposes (TCGA92/S274).

The term ‘ascertained’ has no statutory definition, but the judgement in the case of Stonor and Mills (executors of Margaret Evelyn Dickinson) v CIR (2001) STC (SCD) has approved our approach, which is that for a value to be ascertained some formality or agreement is required and a simple claim is not sufficient.