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HMRC internal manual

Inheritance Tax Manual

Non- Land valuation cases: unlisted share valuation cases

Where a valuation of unlisted shares by Shares and Assets Valuation (SAV) has reached an impasse, you should consider the teamworking arrangements at an early stage.

Where negotiations have failed to reach an agreed value, the SAV Appeals team will ask Litigation to issue a Notice of Determination (NOD). They will ask them to include a value for the shares (usually supported by one of SAV’s panel of independent valuation experts) which can be defended on appeal. Similarly, if the question in dispute is whether Business Relief is available in respect of a shareholding or the extent of the relief, the SAV Appeals Team will ask Litigation to issue a NOD..

The same instructions as for Land NODs apply

  • where there is no appeal (IHTM37055), or
  • an appeal is received (IHTM37056). But in these cases, any hearing will be before the First-tier Tribunal (Tax) rather than the Lands Chamber of the Upper Tribunal.