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HMRC internal manual

Shares and Assets Valuation Manual

Inheritance Tax: Teamworking Arrangements with the IHT Caseworker - Full Enquiries

Where the IHT caseworker is conducting a full enquiry, the Val 70 will be marked prominently to show that the valuation relates to a full enquiry case. Full enquiries will be few in number and will go straight into division (without any initial information gathering) for the attention of an experienced valuer.

On receipt of the valuation request, the valuer should conduct a database search for the deceased/transferor/settlement. He/she should also conduct a database search for and obtain the tax file for the company if this is likely to be productive. [This would not be worthwhile, for example, if the shares under consideration constituted a tiny minority holding in a football club or brewery with which the deceased/transferor had no business connections.]

The valuer should then contact the IHT caseworker to arrange for a meeting to present the information gathered and see how this fits with the case as a whole. The aim should be to hold this meeting within 3 months of the date of the valuation request.

The way forward should be discussed at the meeting and a future review strategy agreed, taking into account SAV’s own strategic approach, given that we may be involved at any one time with more than one valuation and for different taxes.

The issues that are likely to be discussed at the meeting are:-

  • The tax position, including the availability of BR and other reliefs/exemptions;
  • An initial judgement on whether the account or value returned is seriously flawed;
  • How SAV’s role fits in with the other aspects into which the IHT caseworker is raising enquiries;
  • What action SAV has taken and how we see our investigation of the value/availability of reliefs developing;
  • Any problems which either the IHT caseworker or SAV foresees, including, in particular, difficulties in obtaining information/documents. It is likely that difficulties regarding the supply of information will only become apparent as the enquiry develops. You should liaise closely with the IHT caseworker.
  • Information from the database search which is relevant to the enquiry.
  • Information from the tax file that is relevant to charges to IHT or to other taxes such as CGT for example lifetime transfers of shares, or transfers by the company (s.94 IHTA 1984).

This list is not intended to be exhaustive.

The initial case conference on full enquiries will be face-to-face. Subsequent case conferences should be arranged at three-monthly intervals. They may be either face-to face or by telephone. However, if the last conference was by way of a telephone conversation, then the next should be face-to-face.

The IHT caseworker will prepare a full file note of each case conference - and let you have a copy.

You should check the note and clear up any misconceptions.

In view of the regular personal contact it will not be necessary to send written updates where we are valuing for a full IHT enquiry. On the SAV Case Plan, the date of the case conference should be recorded as the date of the customer update.

Some IHT enquiries will only become full enquiries after the valuation request has been issued. When an enquiry becomes a full enquiry at a later date, the IHT caseworker will inform you. Liaison arrangements thereafter will be those appropriate to a full enquiry.

  Additional Guidance: SVM150000