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HMRC internal manual

Shares and Assets Valuation Manual

Inheritance Tax: Inheritance Tax Pre-Grant Foreign Domicile Cases

In certain pre-grant cases where a foreign domicile is claimed, the IHT caseworker may ask SAV to consider and advise informally on the value of unquoted shares and to comment on the availability and extent of business relief. These cases should receive urgent attention at all stages and file movements should be by hand.

On receiving a request, SAV Information Support will (if necessary) obtain the latest accounts from Companies House. Most of these valuation requests are dealt with by Information Support but occasionally it may be necessary to allocate the case for consideration to a general team, or specialist case worker, as appropriate. Such requests must be dealt with as a matter of urgency.

This procedure is designed as a safeguard against a pre-grant foreign domicile case being assessed to tax on the basis of a substantial undervaluation of the unquoted shares when there may be serious problems in obtaining payment of the tax properly due after the grant has been issued.

  Additional Guidance: SVM150000