SVM108290 - Inheritance Tax: Close Companies – Claims under ss.94 – 102 IHTA 1984 generally



Experience has shown that substantial claims tend to arise when almost all the shares are owned by one person (or by spouses). Particular attention should therefore be paid to transactions by "one man" companies.

It is important to note that any such alterations are not PETs.

If, the Team Leader's advice having been sought, there appears to be a prima facie claim and the matter is worth pursuit (having regard to the tax threshold etc.) you should write to the company or relevant agents referring to the transaction, pointing out the appropriate provision and inviting the delivery of IHT accounts. You should also notify Non-Death Compliance Group at the same time by memorandum.

Once a claim is established and the general basis of valuation agreed, the case may continue to be worked normally.


Additional Guidance: SVM150000