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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Reconsideration by HMRC: agreements

An agreement may be either

  • a specific statement by this office that a value has been accepted, or
  • the acceptance by the taxpayers of a value put forward by HMRC - e.g. a VOA (IHTM23002) increase notified to the taxpayers and accepted by them.You must regard an agreement on the value of the property as a bar to seeking to reopen the valuation to establish a higher value unless new material information (

IHTM30441) is received. In certain circumstances this can include sales (IHTM30445).

The operative date for considering whether there is a bar to reopening is the date of acceptance, whether by this office or by the taxpayers - the date of assessment or payment of any additional tax consequential on the agreed value is immaterial.