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HMRC internal manual

Shares and Assets Valuation Manual

Introduction: foreign assets

1 - SAV valuers can also consider the valuation of foreign shares and assets. This includes:

  • The valuation of unquoted shares in overseas companies and other items of foreign property for example foreign land, oil and mineral rights, claims for compensation against foreign governments and, where advice is needed, overseas business interests.
  • The valuation of unquoted shares in UK companies where the business or assets of the company is/are overwhelmingly foreign.
  • Checking and providing prices for shares quoted on overseas Stock Exchanges.
  • Considering claims for reduction in the value of overseas quoted shares on magnitude grounds/special circumstances.
  • Dealing with the valuation aspect of claims for relief for losses on sale of foreign land or quoted shares in IHT cases.
  • Considering negligible value claims in respect of overseas shares for CGT purposes.
  • Conversion into sterling of amounts expressed in foreign currency terms for valuation or double taxation allowance purposes.
  • Applications of the Extra Statutory Concession F6 (formerly known as the Solicitor General’s concession) providing for the deferment of payment of Inheritance Tax (IHT) on overseas assets blocked by foreign exchange control restrictions.

2 - In IHT cases each holding of foreign shares is marked in the Form IHT400 and the file referred to SAV. On receipt, the valuer will:

  • accept the value returned in which case the holding is marked accordingly, or
  • advise IHT Group on correspondence to be sent, or
  • allocate the case to a valuer to investigate the value.

3 - References for valuation of other foreign assets in IHT cases are made by written notation, with or without the file according to the circumstances.

  Additional Guidance: SVM150000