Inheritance Tax: Sub-Threshold Cases - Death
In many instances, unquoted shares will now qualify for 100% BR when the death is on or after 6/4/96, so this paragraph applies only to cases where 100% BR does not apply.
Where the value offered is acceptable it should be accepted on a normal unqualified or ‘without prejudice’ basis, as appropriate. If the referral indicates that based on the value returned the threshold will not be exceeded and the valuation is the only outstanding matter, valuers should first check with the IHT caseworker that there have been no further developments. The IHT caseworker should then be notified that the value will not cause the threshold to be exceeded.
Valuers need to bear in mind that where it is clear the threshold will not be exceeded, the date of death ‘value’ is often inflated so as to attempt to set a higher acquisition cost for CGT purposes.
In other cases where the threshold will not be exceeded but the referral information indicates that there are other outstanding matters, you should notify the IHT caseworker that the threshold will not be exceeded on the aggregate total shown on the referral/spreadsheet and enquire whether negotiations need to be pursued. Wherever possible an estimate of the maximum value of the shares should be supplied.
|Additional Guidance: SVM150000|