IHTM14625 - Fall in value relief: what is a qualifying sale?

Under the provisions of IHTA84/S131 (3), a sale is only a qualifying sale if

  • it is at arm's length for a price freely negotiated at the time of the sale, and
  • no person concerned as vendor (or as having an interest in the proceeds of the sale) is the same as or connected with any person concerned as purchaser (or as having an interest in the purchase), and
  • no provision is made, in or in connection with the agreement for the sale, that the vendor (or any person having an interest in the proceeds of sale) is to have any right to acquire some or all of the property sold or some interest in or created out of it.

If the sale is clearly a straightforward arms length transaction and none of the above complications are indicated, you can accept that the sale is qualifying.

Otherwise, raise any queries with the taxpayer.