HMRC caseworkers do not value assets themselves. Unquoted shares and many other assets go to HMRC’s Shares and Assets Valuation team, and UK property goes to the Valuation Office Agency, which negotiates with your valuer. Most disputes end in an agreed figure; if they stall, HMRC issues a formal decision, such as a closure notice for capital gains tax or a notice of determination for inheritance tax, and the value can then be appealed to the First tier Tribunal or, for property, to a specialist valuation tribunal.

Who at HMRC values the asset?

HMRC’s Shares and Assets Valuation manual (SVM101010) describes Shares and Assets Valuation (SAV) as primarily responsible for valuing shares in companies without a listing on a recognised stock exchange. It also values loans to companies, goodwill, intellectual property, foreign property, Lloyd’s underwriting interests, livestock and bloodstock, bullion, wine, yachts and aircraft, works of art and antiques, among others. Most of its work is for capital gains tax, inheritance tax and employment income.

The Valuation Office Agency (VOA) values UK property, foreign commercial property and plant and machinery. For inheritance tax, HMRC’s Inheritance Tax Manual (IHTM23002) says HMRC relies on the VOA, or the equivalent agency in Northern Ireland, for property in the UK, and most UK property chargeable on a death is referred to it. Where a company owns property, SAV asks the VOA for an opinion on that property before valuing the shares (SVM115010).

The caseworker dealing with your return or IHT account keeps overall control of the case and decides whether to take formal action, but the valuation argument itself is with the specialist.

How do the negotiations work?

SAV guidance (SVM120040) expects valuers to make early telephone contact, discuss points of disagreement, use meetings or calls where they help, and base valuations on facts rather than supposition. Valuers must review each case at least every three months and update the taxpayer at least every three months. A manager reviews any case still open after 12 months, and at 18 months the manager considers whether to refer it to SAV’s Litigation and Technical Advice Team (SVM120060).

The VOA follows a set paper trail on inheritance tax cases. If it cannot accept your figure, it sends its revised valuation on form VO 1001. If there is no response within four weeks it sends a reminder, form VO 1002, waits a further two weeks and then reports back to HMRC (IHTM23132). When agreement is reached the VOA reports the value as “agreed”, or “agreed subject to confirmation” where a surveyor has agreed a figure that the taxpayer has not yet confirmed in writing (IHTM23147 and IHTM23148).

Not every agreement is a full agreement. For capital gains tax, SAV can agree a value outright, accept a returned value without negotiation, agree on a without prejudice basis limited to that transaction, or give an informal opinion (SVM107040). Ask which kind you have, because a without prejudice figure will not be followed automatically next time.

What happens when negotiations stall?

For property in an inheritance tax case, once the VOA reports an impasse HMRC can ask it for an appeal report, endorsed within the VOA’s Chief Executive’s office. HMRC’s options then include issuing a notice of determination, asking the VOA to reopen negotiations, negotiating directly with the taxpayer, or closing the case. If HMRC closes the case, it tells the taxpayer that this does not mean it agrees the value offered, and may send a tax calculation on the taxpayer’s latest figure (IHTM23090).

For shares, the SAV valuer can recommend a notice of determination, but the decision belongs to the IHT caseworker, usually after a case conference. Where little tax is at stake, the guidance allows a pragmatic settlement even if the valuer thinks the figure is not quite right (SVM108180). Where litigation looks likely, the Litigation and Technical Advice Team reviews the case and may take outside expert advice (SVM117020).

For capital gains tax, the valuation is part of an enquiry into the return, so the formal step is the closure notice or an assessment. Our guide to HMRC checks on IHT accounts covers the wider inheritance tax process.

How does a valuation dispute reach a tribunal?

The route depends on the tax and the asset.

Dispute Formal step Where the value is decided
CGT, unquoted shares or other non property assets Appeal against the closure notice or assessment First tier Tribunal (Tax Chamber)
CGT, value of UK property or a lease Appeal against the closure notice or assessment Upper Tribunal in England and Wales; the relevant property tribunals in Scotland and Northern Ireland (section 46D TMA 1970)
IHT, unquoted shares or other assets Appeal against a notice of determination First tier Tribunal (Tax Chamber) (IHTM37060)
IHT, value of UK property Appeal against a notice of determination Upper Tribunal in England and Wales; the relevant property tribunals in Scotland and Northern Ireland (section 222 IHTA 1984)

A dispute about the basis of a property valuation, such as whether it is valued subject to a tenancy or with vacant possession, is treated as a point of principle rather than a pure valuation question (IHTM37051). The appeal process for notices is explained in appealing an IHT notice of determination.

Other people can be affected by a capital gains valuation. Where shares pass between connected persons and holdover relief has not been claimed, regulations allow the recipient to apply to be joined in the formal determination of the value, and SAV then negotiates with both sides (SVM107060).

Can you complain about a valuation instead?

Not about the figure. The Adjudicator’s Office says it cannot look at valuation decisions of statutory officers in the Valuation Office, or at complaints where a tribunal has a specific right to decide the issue. Delay or poor handling by HMRC or the VOA can still be the subject of a complaint; see complaint or appeal.

How does the agreed IHT value affect capital gains later?

Section 274 of the Taxation of Chargeable Gains Act 1992 says that where the value of an asset in a death estate has been ascertained for inheritance tax, whether in proceedings or otherwise, that value is its market value at the date of death for capital gains purposes. SAV guidance notes that even a value accepted on pragmatic grounds below market value becomes the ascertained acquisition value (SVM108180). A low IHT value can therefore mean a larger gain when beneficiaries sell, which is worth weighing before pressing for the lowest possible figure. Our page on CGT valuations covers post transaction valuation checks.

How might a property dispute play out?

Illustration only. Executors include a house in the IHT account at £400,000, based on an estate agent’s letter. The VOA sends form VO 1001 proposing £460,000, pointing to two sales on the same street. The executors instruct a chartered surveyor, who argues the house needed structural repairs and supplies photographs and a builder’s quote. After two rounds of discussion the surveyor and the VOA agree £430,000, and the VOA reports it as agreed subject to confirmation until the executors sign. HMRC then sends a calculation for the extra tax, and £430,000 becomes the beneficiaries’ base cost if they later sell.

Had the two sides stayed apart, HMRC could have asked the VOA for an appeal report and issued a notice of determination, leaving the executors 30 days to appeal.

What mistakes come up most often?

  • Relying on an estate agent’s marketing figure rather than a formal valuation that can be defended in negotiation, as discussed in valuing property for probate.
  • Ignoring a VO 1001 letter, which leads to reminders and then a report back to HMRC.
  • Arguing about the figure when the real dispute is about the basis of valuation, which follows the point of principle route.
  • Treating HMRC’s decision to close a case as acceptance of your value.
  • Forgetting that a low agreed IHT value fixes the beneficiaries’ base cost for capital gains tax.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.