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HMRC internal manual

Inheritance Tax Manual

Related property: apportionment of aggregate value

The value to be included in the deceased/transferor’s estate (IHTM04029) is the ‘appropriate portion’ of the value of the combined unit (IHTM09732). There are two methods of calculating the appropriate portion

  • the general rule (IHTM09735), IHTA84/S161 (3), and
  • the special rule (IHTM09736), IHTA84/S161 (4).

The general rule is used where the items of property (IHTM04030) being aggregated for valuation purposes are different, such as freehold and leasehold interests in the same piece of land. The special rule is mainly used for calculating the value of shareholdings. But it may also be used in some other situations (IHTM09737).