A case conference should be viewed as an opportunity for you
(the IHT case-holder) and SAV valuer to meet, assess all aspects of
progress and decide on the most appropriate course of action.
A case conference should be regarded as mandatory if a case
has not been settled within 12 months of referral to SAV.
Those attending should prepare well in advance so that
informed views can be reached on
Both the valuer and the case-holder should be fully aware of the tax implications of what they are trying to do. A key aim of the case conference is to decide whether the tax at stake, or the precedent setting value, justifies further compliance action.
Prior to a case conference the latest position should be ascertained from the District Valuer. Find out how far apart the parties are and how confident the DV is of his opinion. Get an idea of what value he/she might defend if the case has to go to appeal. Find out if there is any outstanding information which it might be possible to obtain by the IHT caseworker issuing an Information Notice. If the case warrants it be prepared to arrange for the DV to be at the case conference.
Remember that a large difference of opinion over the value of land/property may have only a minimal impact of the value of a minority shareholding. Consider recalling the case from the DV and trying to reach a pragmatic settlement which factors in all the other uncertainties inherent in valuing shares. Even if the value offered is felt to be wrong there could be so little tax is at stake that a without prejudice agreement may be in order.
Consider whether delays being caused by a lack of information. If so decide if it is appropriate to issue an Information Notice. This applies to any outstanding information needed to progress the case, whether it be required by the DV or SAV.
If the outcome is likely to be productive for the case as a whole, consider with the Share Valuer holding a joint meeting with the taxpayer and/or their agent.
