Inheritance Tax: Sub-Threshold Cases - Relevant Property Trusts
Where it appears from Section 6 of the Val 70 (Settlements) or otherwise that the value of the shares will not take the total chargeable value over the tax threshold, and the tax claim relates to a periodic charge or ten-year anniversary charge, valuers should notify the Non-Death Compliance Team of the position and enquire whether negotiations may be discontinued.
See also this chapter at SVM108060 concerning Risk Assessment procedures for 10 year Relevant Property Trust Charges.
Sub-threshold cases involving proportionate charges, however, must still be fully considered where there is a retained shareholding in the company (see Section 2 of the Val 70) or information on the SAV file of other assets retained in the settlement.
If, however, there is no mention of retained assets, valuers should notify the Non Death Compliance Team and enquire whether there are other assets retained in the settlement and, if not, whether negotiations may be closed on the sub threshold basis.
|Additional Guidance: SVM150000|