Technical brief
Apply the correct statutory basis
For inheritance tax, section 160 of the Inheritance Tax Act 1984 defines market value by reference to the price reasonably expected on an open-market sale. This is distinct from the capital gains tax provision in section 272 of TCGA 1992. The report must identify the relevant tax and date.
Assess the holding and available evidence
We consider the size of the interest, voting and economic rights, dividend history, asset backing and maintainable earnings. Subsequent information is used carefully: evidence about conditions at the valuation date is different from a later event that could not then have been anticipated.
Keep value separate from relief
Business Relief eligibility and the rules in force at the date require specialist tax advice. Relief changes do not mechanically change the company’s commercial value. We provide valuation evidence to support the adviser’s reporting and any HMRC discussion; HMRC acceptance is not guaranteed.



