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HMRC internal manual

Inheritance Tax Manual

Special valuation matters: partnership property

If you need to refer land owned by a partnership (IHTM25101) to the VOA (IHTM23002) and 100% business relief (IHTM25021) is not available you should send the VOA a copy of the partnership deed if this is available and tell them on form VOA 3 (IHTM23045) or in a memo

  • that the property is partnership property
  • the deceased partner’s share to be valued
  • the size of all the partners beneficial interests in the partnership assets, or, if that information is unavailable, you should give him details of the number of partners and the way profits are divisible between them, and
  • refer the VOA to Ch1B Section 19

Any case where the taxpayer questions the basis of valuation of partnership property should be referred to TG

It will be rare to have to consider any case where the deceased was a partner in a farming business with an agricultural tenancy. This might be necessary where the farming business is in deficit & a deduction has been claimed or where AR/BR is not available. This type of case needs to be fully investigated. TG will advise on how to quantify this value.