IHTA84/S160 stipulates that the value to be included in the
IHT400 (
IHTM10021) is “the price which
the property might reasonably be expected to fetch if sold in the
open market at that time”.
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000).
Where a valuation is qualified as being made “for
probate purposes” or for “IHT purposes” it may be
appropriate to confirm with the taxpayer that the correct
IHTA84/S160 basis has been used.
As a general statement, post-death sales, particularly those
at auction, provide the best evidence of the open market value at
the date of sale. The taxpayer may be content to substitute the
sale prices for the original valuations or may argue for an
adjustment due to market movement between the dates of death and of
sale. SAV should be consulted if appropriate.
You will occasionally find that the taxpayer will deduct
either the cost of obtaining the valuation or the costs incurred in
sales from the gross value. Please bear in mind that any costs
incurred after the date of death are administration expenses and
therefore not deductible. The auction sale price is the gross
proceeds of sale (or hammer price) before deduction of commission,
insurance etc without addition of any Buyer’s Premium.
The taxpayer will sometimes seek to discount the value due
to the fact that the assets are jointly owned. Please see (
IHTM21043).
