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HMRC Estate Valuation: Common Pitfalls and Professional Solutions

· 20 min

Executive Summary

HMRC conducted 3,977 inheritance tax investigations in the year to April 2025, recovering GBP 246 million in additional tax, with property valuations and undisclosed assets accounting for the majority of disputes.12 The statutory valuation test under IHTA 1984 s.160 requires an open market value assessment, yet the HMRC IHT Toolkit identifies that incorrect valuations based on insurance values, replacement values, or book values remain the most frequently submitted errors.3 With the Valuation Office Agency's absorption into HMRC by April 2026 raising questions about enhanced scrutiny, and APR/BPR reforms from April 2026 introducing a GBP 2.5 million combined allowance that makes agricultural and business property valuations newly consequential, practitioners require asset-class-specific valuation methodologies.45 This article provides a framework covering residential property, jointly owned assets, listed and unquoted shares, household chattels, and agricultural property, together with the penalty regime and loss on sale reliefs that probate accountants and tax advisors must apply.

1. The Valuation Imperative: Why Accuracy Has Never Mattered More

IHT receipts reached a record GBP 8.2 billion in 2024-25, with GBP 7.1 billion collected in the period April 2025 to January 2026 -- GBP 100 million higher year-on-year and on track to surpass the previous record.6 The nil-rate band remains frozen at GBP 325,000 and the residence nil-rate band at GBP 175,000 until April 2030-31, creating sustained fiscal drag that draws an increasing number of estates into the IHT net.7 Receipts are forecast to reach GBP 14.5 billion by 2030-31.8

Against this backdrop, HMRC's enforcement activity has intensified. The 3,977 IHT investigations in 2024-25 represented an increase from 3,793 in the prior year, while 7,500 probate cases were questioned specifically for property valuations, resulting in 1,500 estates being reassessed as undervalued.129 HMRC now deploys AI, data-matching, HM Land Registry cross-referencing, Google Street View, and Trust Registration Service data to identify inconsistencies in IHT returns before formal investigation.129

Two structural developments compound the valuation challenge. First, the Valuation Office Agency is being fully integrated into HMRC by April 2026, removing the institutional separation between the valuing authority and the taxing authority.4 While the government anticipates 5-10% administrative cost savings by 2028-29, concerns have been raised about the potential loss of district valuer independence and the adoption of AI and enhanced data-sharing within the enlarged department for reviewing land use and challenging relief claims.10 Second, the APR/BPR reforms from April 2026 introduce a combined GBP 2.5 million allowance for 100% relief, with 50% relief (an effective 20% IHT rate) applying above that threshold.5 For estates holding qualifying agricultural or business property, the accuracy of the distinction between agricultural value and open market value directly determines relief allocation under the cap.

The thesis of this article is straightforward: estate valuation for IHT purposes is a technical discipline requiring asset-class-specific methodology, not a procedural formality. Each category of estate asset -- residential property, jointly owned assets, shares, chattels, and agricultural property -- demands its own valuation approach, governed by distinct HMRC manual provisions and presenting different investigation risks.

2. The Statutory Framework: IHTA 1984 s.160 and the Open Market Value Test

The foundation of all IHT valuations is section 160 of the Inheritance Tax Act 1984, which defines value as "the price which the property might reasonably be expected to fetch if sold in the open market at that time."11 The statutory test imposes two critical constraints: the price shall not be assumed to be reduced on the ground that the whole property is to be placed on the market at one and the same time, and costs of sale are not deducted from the valuation.1112

HMRC's Inheritance Tax Manual at IHTM09704 elaborates the hypothetical sale assumptions underpinning the open market value test.12 The willing seller is "neither in a rush, nor reluctant, to sell but prepared to sell if offered a reasonable price." The willing buyer is "a prudent person who has the will and money to buy but again is not anxious, nor unduly reluctant, to purchase." The sale is "not sudden or forced." Special purchasers are acknowledged in the market, but their premium does not set the ceiling: the open market value "will be less than what the special buyer is prepared to pay."12

The principle of advantageous lotting, established in Buccleuch v IRC [1967] 1 AC 506, permits an estate to be divided into "natural or appropriate units" for valuation, where doing so produces a higher aggregate value than valuing the estate as a whole.13 Each item is valued at what it would fetch if sold individually, unless lotting produces a higher aggregate -- a principle with significant practical implications for estates containing complementary assets such as land parcels, collections, or business interests.

The related property rules under IHTA 1984 s.161 create a further valuation complexity that practitioners frequently overlook.14 Where property in a person's estate would be valued at less than the appropriate portion of the aggregate of that property and any "related property," the higher aggregate valuation applies. Property is related if comprised in the estate of the person's spouse or civil partner, or held by qualifying charities where transferred by the deceased or their spouse.14

Practical illustration: A husband and wife each hold 40% of a private company's shares, with the remaining 20% held by an unconnected third party. Valued individually, each 40% holding attracts a minority discount. Under the related property rules, the combined 80% holding is valued as a controlling interest, and each spouse's share is assessed as the appropriate portion (one-half) of that aggregate value. The difference between a discounted 40% minority holding and one-half of a controlling 80% holding can be substantial.

The most prevalent error identified in the HMRC IHT Toolkit is the submission of valuations based on insurance values, replacement values, or book values, none of which satisfies the s.160 open market value test.3 Practitioners must ensure that every valuer instructed in connection with an estate is explicitly directed to the s.160 statutory basis.

3. Residential Property: The Highest-Volume Investigation Target

Residential property valuations attract the highest volume of HMRC challenges.9 The HMRC IHT Toolkit classifies property valuation as "an area of high risk" and states that personal representatives are "strongly advised to instruct a qualified independent valuer."3 Valuations must meet RICS or equivalent standards, and HMRC regards it as insufficient to simply refer to a valuer without providing proper instructions: "In the absence of proper instructions the valuer will not understand the context nor have all the necessary details."3

IHTM36275 requires valuers to consider development potential, specifying that "hope value" is a component of open market value that must be explicitly addressed.15 A residential property with a large garden in an area where infill development has occurred, or a property adjacent to land with planning potential, carries hope value that must be reflected in the valuation. Failure to consider hope value is among the most common triggers for HMRC investigation.

The IHT405 schedule requires market valuations at the date of death for all houses, land, and buildings.16 HMRC recommends obtaining three estate agent valuations or a RICS Red Book survey, with self-valuations accepted only in limited circumstances for straightforward, unexceptional properties.316

Common errors in residential property valuation include:

  • Relying on insurance reinstatement values (which reflect rebuilding costs, not market value)
  • Failing to instruct the valuer on the s.160 statutory basis, resulting in a generic "market appraisal" rather than an open market value assessment
  • Omitting development potential or hope value from the valuation
  • Not disclosing property defects, planning restrictions, or access limitations that affect value
  • Failing to reconcile where a property sells for significantly more than probate value within six months of death, which HMRC treats as prima facie evidence of undervaluation17

The VOA/District Valuer referral process provides an independent check on property values, and HMRC may refer properties to the District Valuer where the submitted value appears inconsistent with comparable evidence.15 With the VOA's absorption into HMRC by April 2026, the District Valuer function continues but within an enlarged departmental structure, and practitioners should monitor whether this integration affects the referral process or the independence of district valuer assessments.

Jointly owned property presents a distinct set of valuation challenges. The starting point for co-owned property discounts under IHTM15072 is a 10% reduction from the arithmetical share, increasing to 15% where the surviving co-owner occupies the property as their main residence.18 These are starting points only, and the appropriate discount depends on the specific circumstances of each case.

A critical distinction that practitioners must observe is the treatment of spousal co-ownership. No joint ownership discount applies where co-owners are spouses or civil partners, because the related property rules under s.161 aggregate the holdings and value each share as the appropriate portion of the combined interest.1814 Applying a 10% or 15% discount to a spouse's share of a jointly owned property is an error that the related property rules directly override.

Where a District Valuer provides a valuation of a joint interest, that valuation already incorporates the appropriate discount; practitioners should not apply a further reduction on top of the District Valuer's figure.18

Worked example: A deceased held a 50% share in a property valued at GBP 600,000 in total. The co-owner is an unrelated adult child who occupies the property as their main residence.

  • Arithmetical share: GBP 300,000
  • 15% joint ownership discount (occupied by co-owner as main residence): GBP 45,000 reduction
  • Value for IHT purposes: GBP 255,000

If instead the co-owner were the deceased's spouse, the related property rules aggregate the holdings. The deceased's share is valued as one-half of the GBP 600,000 total = GBP 300,000, with no joint ownership discount applied.

The IHT404 schedule requires details of all jointly owned assets, including when joint ownership began, the identity of co-owners, and contribution proportions.19 HMRC investigates the circumstances of joint ownership creation, particularly where ownership was recently transferred, and considers gifts with reservation of benefit implications where the deceased contributed disproportionately to the acquisition.2021

5. Stocks, Shares, and Financial Assets

Listed shares

Listed shares are valued using the "quarter-up" method under IHTM18093: the lower closing price, plus one quarter of the difference between the lowest and highest closing prices of the day.22

Worked example: On the date of death, a share has a low price of 1091p and a high price of 1101p. The quarter-up calculation is: 1091 + (1101 - 1091) / 4 = 1091 + 2.5 = 1093.5p.22

Where death occurs on a non-trading day (weekend or bank holiday), practitioners use either the last trading day before or the first trading day after death, whichever produces the lower value.22

Unit trusts and OEICs are valued at the bid price at the date of death. ISA holdings are valued as if not held within an ISA wrapper.

Unquoted shares

Valuations of unquoted shares are handled by HMRC's Shares and Assets Valuation (SAV) division, which practitioners can contact at savexternal.mailbox@hmrc.gov.uk.23 The open market value test applies: "the price you would expect in an open market sale between a hypothetical willing seller and a hypothetical willing buyer."23 Minority holding discounts, lack of marketability discounts, and control premiums are all relevant factors.24 Self-valuations of significant private company holdings carry material investigation risk, and SAV referral is the prudent course for any holding where the valuation is expected to exceed GBP 150,000 or where the business is complex.

The APR/BPR reforms from April 2026 make share valuations for qualifying businesses newly consequential. Where total qualifying assets exceed the GBP 2.5 million combined allowance, the accuracy of the valuation determines the allocation between 100% and 50% relief -- a distinction that directly affects the estate's IHT liability.5

Loss on sale of shares relief (IHTA 1984 ss.178-179)

Where qualifying listed investments are sold within 12 months of death at an overall loss, the loss on sale of shares relief under ss.178-179 permits the substitution of the sale price for the date-of-death value.25 Critically, the claim must include all qualifying investment sales within the 12-month period, not merely the loss-making disposals. AIM-traded shares do not qualify as "qualifying investments" for this relief.25 The claim deadline is four years from the end of the 12-month qualifying period.

6. Household Goods, Chattels, and Personal Effects

Household goods and personal effects are valued on the s.160 open market value basis -- the price they would fetch on the open market, not their insurance or replacement cost.26 IHTM21041 states that professional valuations confirming compliance with the s.160 basis are generally acceptable, and that sales after death, particularly at auction, provide "the best evidence of open market value at the date of sale."26

Self-valuation is permitted for ordinary household goods where individual items are valued at no more than GBP 500, and HMRC accepts the executor's reasonable estimate without specialist valuation where total household goods are valued below GBP 1,500.327 Items of jewellery worth over GBP 1,500 must be individually listed on the IHT407 schedule.28

Common errors include:

  • Using insurance or replacement values, which reflect the cost of acquiring a new equivalent item rather than what the used item would fetch on resale -- potentially overstating value and creating unnecessary IHT liability
  • Failing to identify and separately value antiques, artwork, vintage jewellery, wine collections, vintage motor vehicles, and other collectibles that may significantly exceed general household goods values
  • Omitting items altogether, which the HMRC IHT Toolkit identifies as a primary investigation trigger23

Overvaluation of chattels through inflated insurance figures is a frequently overlooked risk. An estate that submits insurance values for household goods may be paying IHT on a value that significantly exceeds what the items would realise on the open market, with no mechanism for correction unless the items are subsequently sold.

7. Agricultural and Business Property: The APR/BPR Valuation Challenge

Agricultural property relief under IHTA 1984 s.115(3) applies to the "agricultural value" of agricultural property -- the value assuming the property could only ever be used for agricultural purposes.29 The distinction between agricultural value and open market value is critical where property has development potential, amenity value, or alternative use value. A 200-acre farm with land fronting a village may have agricultural value of GBP 10,000 per acre but open market value (reflecting residential development potential) of GBP 50,000 per acre. APR applies only to the agricultural value; the excess is subject to IHT unless BPR applies.

The April 2026 reforms amplify this distinction. The combined GBP 2.5 million allowance for 100% APR/BPR relief means that accurate valuation of qualifying agricultural property directly determines how much relief is claimed at 100% versus 50%.5 An estate with GBP 3 million of agricultural value and GBP 1 million of non-agricultural value attached to the same property achieves 100% APR on GBP 2.5 million, 50% APR on GBP 500,000, and no relief on the GBP 1 million non-agricultural element (subject to any available NRB). An inaccurate valuation that conflates agricultural and open market values may misallocate relief and trigger HMRC investigation.

District Valuer referral is appropriate to determine both the agricultural value and the open market value of agricultural property.30 Given the financial significance of this distinction under the reformed regime, early engagement with the District Valuer -- before submission of the IHT400 -- represents a risk management measure.

The residence-based IHT regime, enacted from 6 April 2025 under the Finance Act 2025, replaced the domicile-based system with a long-term UK residence test (broadly, UK tax resident for at least 10 of the previous 20 tax years).31 The updated IHT400 and IHT100 forms incorporate new schedules (IHT401a, D31a, D31b) for deceased persons who are not long-term UK residents, and practitioners must confirm whether the residence-based regime affects the scope of assets within the estate, including agricultural and business property held overseas.32 Cryptoassets must now be confirmed and reported in box 76 of the IHT400 with details provided in the "Additional information" section.33

8. The Penalty Framework: Consequences of Inaccurate Valuation

Two penalty regimes govern inaccurate IHT accounts, and practitioners must identify which applies to the estate in question.

Late delivery penalties (IHTA 1984 s.245):

  • 0-6 months late: GBP 100 initial penalty
  • 6-12 months late: further GBP 100 (total GBP 200)
  • Over 12 months late: additional penalties up to GBP 3,000, scaled by tax liability
  • Tax liability exceeding GBP 1 million: GBP 400 per month beyond the 12-month threshold
  • Reasonable excuse defence available34

Inaccuracy penalties -- deaths before 1 April 2009 (IHTA 1984 s.247):

The legacy inaccuracy penalty under s.247 applies only to deaths occurring before 1 April 2009.35 Under this regime, the maximum penalty for an inaccurate IHT account is 100% of the culpable tax for accounts delivered after 22 July 2004.35 The penalty applies where an account omits property or fails to include property at its open market value; it does not apply to incorrect tax calculations, only to incorrect valuations or disclosures.36

Inaccuracy penalties -- deaths on or after 1 April 2009 (Finance Act 2007 Schedule 24):

For the vast majority of current probate work, the inaccuracy penalty regime is governed by Finance Act 2007 Schedule 24, as extended to IHT by Finance Act 2008 Schedule 40.37 This regime operates on a graduated structure based on culpability:

  • Careless inaccuracy: maximum penalty of 30% of the potential lost revenue
  • Deliberate but not concealed inaccuracy: maximum penalty of 70% of the potential lost revenue
  • Deliberate and concealed inaccuracy: maximum penalty of 100% of the potential lost revenue37

Penalties under Schedule 24 are reducible for disclosure quality -- the degree to which the person tells HMRC about the inaccuracy, helps to quantify it, and provides access to records. An unprompted disclosure attracts greater reduction than a prompted one.37

What constitutes "carelessness" in the valuation context extends beyond wilful misstatement. Failure to obtain professional valuation advice for complex assets, failure to instruct valuers on the correct s.160 statutory basis, and failure to consider and disclose development potential or hope value may each constitute careless inaccuracy triggering penalty liability. Personal representatives can be personally liable for underpayment arising from negligent valuation -- a risk that reinforces the need for documented professional methodology.

9. Loss on Sale Reliefs: The Safety Net Practitioners Overlook

Two loss on sale reliefs provide a mechanism for correcting valuation outcomes where assets decline in value after death, yet both remain significantly underutilised in practice.

Loss on sale of shares (IHTA 1984 ss.178-179): As noted in Section 5, qualifying listed investments sold within 12 months of death at an overall loss permit substitution of the sale price for the date-of-death value.25 The requirement to include all qualifying sales in the claim means that gains on some holdings may offset losses on others, reducing or eliminating the benefit. Practitioners should track all post-death investment disposals against probate values throughout the 12-month window.

Loss on sale of land (IHTA 1984 ss.190-191): Interests in land sold within four years of death qualify for substitution of the sale price for the date-of-death value.38 The minimum threshold requires the difference to exceed GBP 1,000 or 5% of the death value, whichever is lower. Once claimed, all land sold within the four-year period must use sale prices -- including sales above probate value -- meaning that a property sold at a gain may partially or wholly offset a loss on another.38 The claim is made using form IHT38.39

Practical implications: Estates should establish a tracking protocol from the outset of administration, recording all post-death asset disposals against probate values. The interaction with capital gains tax base cost is a further consideration: where the sale price is substituted for IHT purposes, the beneficiary's CGT base cost is also adjusted to the sale price, which may create a CGT liability on a subsequent disposal if the asset is not the one sold. Timing decisions -- whether to delay a sale to fall within or outside the qualifying period -- require modelling of both the IHT saving and the CGT consequences.

Conclusion

Estate valuation for IHT purposes is a technical discipline that demands different methodologies for each asset class, grounded in the statutory framework of IHTA 1984 s.160 and the specific HMRC manual provisions governing each category. The cost of casual valuation is quantifiable: GBP 246 million recovered through HMRC investigations in 2024-25, penalties of up to 100% of the potential lost revenue under the Finance Act 2007 Schedule 24 regime, personal liability for personal representatives, and the intangible but significant cost of prolonged HMRC enquiry.

The cost of rigorous valuation is equally quantifiable: reduced investigation risk through RICS-standard property valuations and SAV referral for unquoted shares; optimal IHT positions through correct application of joint ownership discounts and related property rules; and material tax savings through timely loss on sale claims where asset values decline post-death.

Two developments make this discipline more consequential than at any prior point. The VOA's absorption into HMRC by April 2026 raises questions about the intensity of property valuation scrutiny within an enlarged department. The APR/BPR reforms from April 2026, introducing the GBP 2.5 million combined allowance, mean that the accuracy of agricultural and business property valuations directly determines relief allocation under the cap. Practitioners who treat estate valuation as an advisory competency rather than a procedural formality position themselves to deliver materially better outcomes for estates while managing their own professional risk.

The cross-referral protocol is essential: RICS surveyors for residential and agricultural property, SAV for unquoted shares, specialist chattels valuers for significant collections and high-value personal effects, and agricultural valuers for the agricultural value/open market value distinction. Each professional instruction must reference the IHTA 1984 s.160 open market value basis. Documentation of the methodology applied, the professionals instructed, and the bases of valuation provides the evidential foundation that withstands HMRC scrutiny.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Inheritance Tax, Estate Administration, Probate Accounting, Property Valuation

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the statutory valuation test under IHTA 1984 s.160 and distinguish it from insurance, replacement, and book value bases
  2. Apply the correct valuation methodology for each major asset class in an estate: residential property, jointly owned assets, listed and unquoted shares, and household chattels
  3. Evaluate the impact of the related property rules (IHTA 1984 s.161) on the valuation of assets held by spouses or civil partners
  4. Analyse the penalty framework under IHTA 1984 s.245 and Finance Act 2007 Schedule 24 and assess the consequences of careless or inaccurate estate valuations

ICAEW/CIOT Competency Mapping

  • Tax compliance: IHT compliance and estate valuation methodology across property, shares, and specialist assets
  • Technical analysis: Coordination with valuers, SAV, and specialist professionals for multi-asset estate administration and dispute resolution

Reflective Questions

  1. How would the VOA's absorption into HMRC from April 2026 affect the approach to obtaining and presenting property valuations for IHT purposes within the practice?
  2. What procedures could be implemented to ensure that valuers are properly instructed on the IHTA 1984 s.160 open market value basis when completing estate valuations?
  3. In what circumstances would the loss on sale of land or shares relief provide a material benefit for estates, and how should post-death asset tracking be structured to preserve this option?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 24 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. HMRC Inheritance Tax Statistics Commentary: Inheritance Tax liabilities statistics. https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-statistics-commentary ↩ ↩2 ↩3

  2. Money Marketing: IHT investigations grow, recovering an extra GBP 246m. https://www.moneymarketing.co.uk/news/iht-investigations-grow-recovering-an-extra-246m/ ↩ ↩2 ↩3 ↩4

  3. HMRC Inheritance Tax Toolkit. https://www.gov.uk/government/publications/hmrc-inheritance-tax-toolkit ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  4. GOV.UK: Valuation Office Agency scrapped in government drive to slash inefficiencies (28 April 2025). https://www.gov.uk/government/news/valuation-office-agency-scrapped-in-government-drive-to-slash-inefficiencies ↩ ↩2

  5. GOV.UK: Agricultural property relief and business property relief changes (December 2025). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2 ↩3 ↩4

  6. HMRC Tax Receipts and National Insurance Contributions Monthly Bulletin (February 2026). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin ↩

  7. GOV.UK: Inheritance Tax thresholds. https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  8. GOV.UK: Budget 2025 document. https://www.gov.uk/government/publications/budget-2025-document/budget-2025-html ↩

  9. Pie.tax: HMRC Hits 1,500 Families with Higher Inheritance Tax. https://www.pie.tax/tax-pible/hmrc-hits-1500-families-higher-inheritance-tax ↩ ↩2 ↩3

  10. CLA: The absorption of the Valuation Office Agency into HMRC -- What it means for UK property owners. https://www.cla.org.uk/news/the-absorption-of-the-valuation-office-agency-into-hmrc-what-it-means-for-uk-property-owners/ ↩

  11. Inheritance Tax Act 1984 Section 160. https://www.legislation.gov.uk/ukpga/1984/51/section/160 ↩ ↩2

  12. HMRC Inheritance Tax Manual IHTM09704: Valuation -- main features of a sale in the 'open market'. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm09704 ↩ ↩2 ↩3

  13. HMRC Inheritance Tax Manual IHTM09715: Valuing property in an estate -- valuing items of property separately. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm09715 ↩

  14. Inheritance Tax Act 1984 Section 161: Related property. https://www.legislation.gov.uk/ukpga/1984/51/section/161 ↩ ↩2 ↩3

  15. HMRC Inheritance Tax Manual IHTM36275: Improving future compliance -- valuations of land. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm36275 ↩ ↩2

  16. GOV.UK: IHT400 Guidance Notes. https://www.gov.uk/government/publications/inheritance-tax-inheritance-tax-account-iht400 ↩ ↩2

  17. My Tax Accountant: How Does HMRC Treat a House Sold For More than Probate Value? https://www.mytaxaccountant.co.uk/post/house-sold-more-than-probate-value ↩

  18. HMRC Inheritance Tax Manual IHTM15072: Valuation of joint property -- discounts for joint ownership. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm15072 ↩ ↩2 ↩3

  19. HMRC Inheritance Tax Manual IHTM15022: Investigation of form IHT404 -- what information does form IHT404 contain? https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm15022 ↩

  20. HMRC Inheritance Tax Manual IHTM15023: Investigation of form IHT404 -- general investigation points. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm15023 ↩

  21. HMRC Inheritance Tax Manual IHTM15061: Investigation of form IHT404 -- Gifts with reservation. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm15061 ↩

  22. HMRC Inheritance Tax Manual IHTM18093: Stocks and shares -- valuation -- shares. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm18093 ↩ ↩2 ↩3

  23. GOV.UK: Shares and assets valuations for tax. https://www.gov.uk/guidance/shares-and-assets-valuations-for-tax ↩ ↩2

  24. HMRC Shares and Assets Valuation Manual SVM108070: Inheritance Tax -- General Approach to IHT Valuation Requests. https://www.gov.uk/hmrc-internal-manuals/shares-and-assets-valuation-manual/svm108070 ↩

  25. HMRC Inheritance Tax Manual IHTM34011: Loss on sale of shares -- basic conditions. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm34011 ↩ ↩2 ↩3

  26. HMRC Inheritance Tax Manual IHTM21041: Household goods and personal goods -- valuation and technical issues -- how we value household goods. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm21041 ↩ ↩2

  27. The Gazette: How to value a house and its contents for probate. https://www.thegazette.co.uk/all-notices/content/103591 ↩

  28. HMRC Inheritance Tax Manual IHTM21000: Household and personal goods -- contents. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm21000 ↩

  29. HMRC Inheritance Tax Manual IHTM24150: Value and Valuation -- Agricultural value of agricultural property. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm24150 ↩

  30. HMRC Inheritance Tax Manual IHTM24160: The District Valuer -- Introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm24160 ↩

  31. Finance Act 2025 c.8 Part 2 Chapter 4 (Inheritance Tax: Long-term UK resident). https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩

  32. HMRC Trusts and Estates Newsletter: April 2025. https://www.gov.uk/government/publications/hm-revenue-and-customs-trusts-and-estates-newsletters/hmrc-trusts-and-estates-newsletter-april-2025 ↩

  33. HMRC Trusts and Estates Newsletter: February 2026. https://www.gov.uk/government/publications/hm-revenue-and-customs-trusts-and-estates-newsletters/hmrc-trusts-and-estates-newsletter-february-2026 ↩

  34. HMRC Inheritance Tax Manual IHTM36023: Late accounts -- penalties chargeable. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm36023 ↩

  35. HMRC Inheritance Tax Manual IHTM36103: Incorrect account, information or document -- s.247(1) penalty. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm36103 ↩ ↩2

  36. HMRC Inheritance Tax Manual IHTM36101: Incorrect account, information or document -- when is an account, information or document incorrect? https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm36101 ↩

  37. Finance Act 2007 Schedule 24: Penalties for Errors; HMRC Compliance Handbook CH80000 series. https://www.legislation.gov.uk/ukpga/2007/11/schedule/24 ↩ ↩2 ↩3

  38. HMRC Inheritance Tax Manual IHTM33011: Loss on sale of land -- outline of the relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm33011 ↩ ↩2

  39. HMRC Inheritance Tax Manual IHTM33022: Loss on sale of land -- procedures -- issuing form IHT38. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm33022 ↩

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