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HMRC internal manual

Inheritance Tax Manual

Reconsideration by taxpayers: changed circumstances

The offer to pay tax on a higher value may reflect a correction to

  • the nature or character of the property or interest to be valued so that in effect we now have to value different property, or
  • other information on which the original valuation was based.

This may be because the taxpayers have received further information to the effect that, for example

  • property previously valued subject to a statutory tenancy should be valued with vacant possession
  • property is freehold (IHTM23001), not leasehold as previously thought, or
  • the extent of the deceased’s share or interest is greater than originally disclosed.

Refer the case to your manager if it seems that

  • the property to be valued may have to be redefined, or
  • the original valuation was based on wrong or misleading information.

In other cases you are free to consider whether to accept offers of tax on a higher value, e.g. on a sale of the property in question.

If the taxpayer offers to pay tax on what seems to be an unduly high value, you should consider a referral to the appropriate valuation specialist for advice.