IHTM25104 - Valuing the partnership interest: Freehold and leasehold property

This is a very common item in partnership balance sheets and its inclusion almost certainly means that it is property which belongs to the partnership.

You should obtain full details of the property on form IHT405 ( IHTM23011) and then refer to the VOA ( IHTM23002) (except in the rare case involving fetters) ( IHTM25120). You should send the VOA a copy of the partnership deed if this is available and tell them on form VOA 3 ( IHTM23045) or in a memo

• that the property is partnership property
• the deceased partner’s share to be valued
• the size of all the partners beneficial interests in the partnership assets, or, if that information is unavailable, you should give them details of the number of partners and the way profits are divisible between them, and
• refer the VOA to Ch1B Section 19

Any case where the taxpayer questions the basis of valuation of partnership property or a discount is claimed on the VO’s opinion of value should be referred to Technical Group (TG) .