IHTM23081 - Interim reports: introduction

There will be occasions during valuation negotiations where it will be appropriate to take stock of the matters at issue and to consider whether or not to bring negotiations to an end. These opportunities arise when the VOA ( IHTM23002) makes an interim report on form VO 1103.

There are no definitive rules about when to close a case, assuming no point of principle is at issue. An overall value judgement needs to be taken, reflecting all the prevailing circumstances including

• the size of the estate
• the tax at stake ( IHTM23082)
• the strength of the respective arguments
• the extent of the supporting evidence of comparables
• whether the taxpayer's figure is within an acceptable range of value
• the need to make a balanced judgement that is fair to the general body of taxpayers

The decision should not simply be taken on the basis of the tax at stake alone. You may need to talk to the VOA to obtain an overall impression of the circumstances of the case or to liaise with Litigation ( IHTM23083). In cases of doubt you should also consult your Team Leader (if you are in Compliance Group) or refer the file to the Primary Compliance Support Team (if you are in PC&S).