IHTM14670 - Fall in value relief: leases

You may need to make an adjustment to the market values (IHTM14626) where the transferred property is

  • a leasehold interest,
  • having not more than fifty years to run at the time of the chargeable transfer.

Make an adjustment to the market value of the property transferred at the date of death or sale.

Increase the value at the relevant date by the formula:


P(1) - P(2) ÷ P(1) × mv


  • mv is the market value at the time of the chargeable transfer.
  • P(1) and P(2) are the percentages derived from the table below (which comes from Para 1 Sched 8 TCGA 1992) by reference to
  • the length of the lease at the time of the chargeable transfer - P(1), and
  • the length of the lease at the date of death or sale - P(2).

Years

Percentage

Years

Percentage

50 or more

100.000

 

25

81.100

49

99.657

 

24

79.622

48

99.289

 

23

78.055

47

98.902

 

22

76.399

46

98.490

 

21

74.635

45

98.059

 

20

72.770

44

97.595

 

19

70.791

43

97.107

 

18

68.697

42

96.593

 

17

66.470

41

96.041

 

16

64.116

40

95.457

 

15

61.617

39

94.842

 

14

58.971

38

94.189

 

13

56.167

37

93.497

 

12

53.191

36

92.761

 

11

50.038

35

91.981

 

10

46.695

34

91.156

 

9

43.154

33

90.280

 

8

39.399

32

89.354

 

7

35.414

31

88.371

 

6

31.195

30

87.330

 

5

26.722

29

86.226

 

4

21.983

28

85.053

 

3

16.959

27

83.816

 

2

11.629

26

82.496

 

1

5.983

 

 

 

0

0.00

If the duration of the lease is not an exact number of years, use the percentage for the whole number of years plus one twelfth of the difference between that and the percentage for the next highest number of years for each odd month, counting an odd 14 days or more as one month.

Example

A lease having exactly four years to run is transferred on 31 December 1986 when worth £20,000. The transferor dies on 31 December 1988, when the lease is worth £5,000. Under the table, P(1) is 21.983 and P(2) is 11.629.

For relief purposes, increase the £5,000 by

(21.983 - 11.629) ÷ 21.983 × £22,000 = £9,420


to £14,420.

Note

Also consider whether the lease, being an interest in land, is subject to amendments for any changes (IHTM14661) that have occurred during the relevant period.