In many instances, unquoted shares will now qualify for 100% BR
when the death is on or after 6/4/96, so this paragraph applies
only to cases where 100% BR does not apply.
Where the value offered is acceptable it should be accepted
on a normal unqualified or 'without prejudice' basis, as
appropriate. Otherwise if Sections 8 and 9 of the Val 70 (Death)
indicate that the threshold covers
and the valuation is the only outstanding matter
valuers should first check with the IHT caseworker that there have
been no further developments. The IHT caseworker should then be
notified that the value will not cause the threshold to be
exceeded. At the same time valuers should write to the agents
informing them that on the basis of the information we have, it
appears that the IHT threshold will not be exceeded, and that
therefore it is not proposed to negotiate or agree a value for the
shares on this occasion.
In such cases you should make it clear thatthis course of action is without prejudice to any other
valuation required for anyHMRC purpose and in particular that the value has not been
‘ascertained’ for IHTpurposes within the meaning of s.274 TCGA 1992.
Valuers need to bear in mind that where it is clear the threshold
will not be exceeded, the date of death ‘value’ is
often inflated so as to attempt to set a higher acquisition cost
for CGT purposes.
In other cases where the threshold appears to cover but
Section 8 of the Val 70 indicates that there are other outstanding
matters, you should notify the IHT caseworker that the threshold
will not be exceeded on the aggregate total shown on the Val 70 and
enquire whether negotiations need to be pursued. Wherever possible
an estimate of the maximum value of the shares should be supplied.
If the IHT caseworker then confirms that negotiations need not
proceed, a letter should be sent to the agents in similar terms to
those at paragraph 2 above.
| Additional Guidance: SVM150000 |
