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HMRC internal manual

Inheritance Tax Manual

Issues that may arise after receipt of the VOA’s final report: re-opening valuations

If an agreed report has been received from the VOA (IHTM23002), you should not normally look to re-open the valuation unless

  • the taxpayer produces fresh information to support a lower valuation, or
  • they volunteer to pay tax on an increased value (but see the instructions on clearance certificates (IHTM40001) if a statutory certificate of discharge has been issued).

If you receive an application to re-open the valuation and the value can be re-opened refer the papers back to the VOA with an explanation of the reason why the value is to be re-opened. Before doing so, consult your Team Leader (if you are in Compliance Group) or refer the case to TSS (if you are in PC&S).

Instructions elsewhere in this section deal in detail with sales (IHTM23185) of property under a binding contract entered into after the death and loss on sale of land relief (IHTM33001). In the former situation, it may be appropriate to refer back to the VOA or to consult the taxpayer about the potential effect of the sale on the date of death value.